Shane Michael Optical, Co. - Page 2




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          separately petitioned the Court to redetermine respondent's                 
          determinations as to their 1993, 1994, and 1995 taxable years.              
          Respondent determined that Shane Michael was liable for accuracy-           
          related penalties under section 6662(a) of $2,091, $3,379, and              
          $2,437, respectively, and that it was liable for a $1,704                   
          addition to its 1994 tax under section 6651(a)(1).  Respondent              
          determined that the Shanes were liable for accuracy-related                 
          penalties under section 6662(a) of $5,653, $6,244, and $8,043,              
          respectively, and that they were liable for a $1,557 addition to            
          their 1994 tax under section 6651(a)(1).                                    
               Respondent concedes that none of petitioners are liable for            
          the additions to tax.  Thus, we are left to decide whether Shane            
          Michael and the Shanes are liable for the accuracy-related                  
          penalties.  We hold they are not.  Unless otherwise stated,                 
          section references are to the Internal Revenue Code in effect for           
          the years in issue.  Rule references are to the Tax Court Rules             
          of Practice and Procedure.                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  The stipulated                
          facts and the exhibits submitted therewith are incorporated                 
          herein by this reference.  When the Court filed the respective              
          petitions, Shane Michael's legal address was in San Francisco,              
          California, and the Shanes resided in San Mateo, California.                








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