














                                 T.C. Memo. 2003-24                                   


                               UNITED STATES TAX COURT                                


                   PAUL F. AND ELEANORE M. NICHOLS, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6725-01.                Filed January 27, 2003.             


               Paul F. and Eleanore M. Nichols, pro sese.                             
               Jeremy L. McPherson, for respondent.                                   


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioners petitioned the Court to                      
          redetermine respondent’s determination that they are liable for             
          Federal income tax deficiencies for 1997 and 1998 of $59,117 and            
          $62,558, respectively, and for accuracy-related penalties under             
          section 6662(a) of $11,823.40 and $12,511.60.                               
               We decide the following issues:

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