Andrew J. and Marilyn Welch - Page 1

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                                 T.C. Memo. 2002-39                                   


                               UNITED STATES TAX COURT                                


                     ANDREW J. AND MARILYN WELCH, Petitioners v.                      
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     


               Docket No. 16459-99.             Filed February 11, 2002.              


               Douglas M. Edwards, for petitioners.                                   
               Rodney J. Bartlett, for respondent.                                    


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               SWIFT, Judge:  Relating to Federal income tax deficiencies             
          that respondent determined against petitioners, respondent                  
          determined against petitioners additions to tax for 1980, 1982,             
          and 1983 as follows: