litigation.   She is a petitioner in these

proceedings solely because she filed joint Federal income tax

returns with Ballard for the years at issue.

     C.   Robert W. Lisle (STJ report at 22-23)

     Lisle was also an employee of Prudential from September 1950

to April 1982.   He was also employed in the real estate

department at Prudential, in real estate development and in
                               -44-

mortgage financing.   The development aspect of his work was

conducted under the umbrella of a subsidiary corporation of

Prudential, which was known as PIC Realty Corp.(PIC Realty).

Lisle was president of PIC Realty.    Prudential conducted its real

estate equity and joint venture operations in the name of PIC

Realty in those States that prohibited insurance corporations

from directly engaging in real estate development.   To a large

extent, the career of Lisle paralleled that of Ballard.    Lisle

also worked in various regional offices of Prudential and

ultimately was promoted to a senior executive position at

Prudential’s Newark corporate headquarters.   The offices of Lisle

and Ballard were next door to each other.   At the time Lisle left

Prudential in 1982, he was a vice president of Prudential.

Lisle’s supervisor at Prudential was also Donald Knab.    After

leaving Prudential in April 1982, Lisle worked for The Travelers

Insurance Co. (Travelers) until April 1988, doing