Fernando and Maria Leonzo - Page 1

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                                 T.C. Memo. 1997-59                                   


                               UNITED STATES TAX COURT                                


                      FERNANDO AND MARIA LEONZO, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14021-93.              Filed February 3, 1997.              


               Fernando and Maria Leonzo, pro se.                                     
               Aretha Jones, for respondent.                                          


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COHEN, Chief Judge:  Respondent determined deficiencies in,            
          additions to, and a penalty on, petitioners' Federal income taxes           
          as follows:                                                                 
                                   Additions to Tax and Penalty                       
          Year      Deficiency     Sec. 6653(a)(1)  Sec. 6661(a)  Sec. 6662           
          1988      $23,444.18     $1,172.21      $5,861.00     ---                   
          1989   4,473.00       ---            ---        $894.60