Jack R. Prewitt and Shelley Prewitt - Page 1

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                                 T.C. Memo. 1995-487                                  


                               UNITED STATES TAX COURT                                


                 JACK R. PREWITT AND SHELLEY PREWITT, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3665-92.          Filed October 10, 1995.                   


               Jack R. Prewitt and Shelley Prewitt, pro sese.                         
               Howard P. Levine, for respondent.                                      


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GERBER, Judge:  Respondent determined deficiencies in and              
          additions to Federal income tax for petitioners' 1980 through               
          1983 taxable years as follows:                                              
                     Additions to Tax                                                 
          Sec.        Sec.         Sec.      Sec.                                     
          Year  Deficiency   6653(b)   6653(b)(1)   6653(b)(2)   6661                 
          1980   $5,393     $3,745.50      ---         ---        ---                 
          1981    3,235      1,617.50      ---         ---        ---                 
          1982   10,622         ---     $6,879.50       1      $2,655.50              
          1983   91,531         ---     45,765.50       1      22,882.75              
               1 50 percent of the interest due on the deficiency.