William Barry Blythe and Cheryl Lynn Blythe - Page 1

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                                 T.C. Memo. 1999-11                                   


                               UNITED STATES TAX COURT                                


             WILLIAM BARRY BLYTHE AND CHERYL LYNN BLYTHE, Petitioners v.              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 13949-97.                 Filed January 22, 1999.           


               William Barry and Cheryl Lynn Blythe, pro sese.                        
               Karen Nicholson Sommers, for respondent.                               


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               CHIECHI, Judge:  Respondent determined a deficiency in                 
          petitioners' Federal income tax (tax) and an accuracy-related               
          penalty under section 6662(a)1 for taxable year 1994 in the                 
          amounts of $15,404 and $3,081, respectively.                                
               The issues remaining for decision are:                                 

               1  All section references are to the Internal Revenue Code             
          (Code) in effect for the year at issue.  All Rule references are            
          to the Tax Court Rules of Practice and Procedure.