Sidney C. Shaw - Page 1

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                                 T.C. Memo. 2002-35                                   


                               UNITED STATES TAX COURT                                


                            SIDNEY C. SHAW, Petitioner v.                             
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     


               Docket No. 2799-00.             Filed February 6, 2002.                


               H. Craig Pitts, for petitioner.                                        
               Edith F. Moates, for respondent.                                       


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COHEN, Judge:  Respondent determined deficiencies and                  
          accuracy-related penalties with respect to petitioner’s Federal             
          income tax as follows:                                                      
                                                Penalty, I.R.C.                       
                     Year        Deficiency      Sec. 6662(a)                         
                     1995       $75,255       $15,051                                 
                     1996       103,514       20,703