Joseph and Annie Chu - Page 1

                                 T.C. Memo. 1996-549                                  

                               UNITED STATES TAX COURT                                

                        JOSEPH AND ANNIE CHU, Petitioners v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 142-95, 22884-95.       Filed December 18, 1996.           

                    Ps owned and operated a retail gift store, and                    
               they deposited the stores' proceeds into bank accounts                 
               owned or controlled by them.  R determined that the                    
               amounts of these deposits were includable in Ps' gross                 
               income for the year of deposit.  R also determined that                
               Ps did not report certain interest income, and that Ps                 
               were liable for accuracy-related penalties under                       
               sec. 6662(a), I.R.C.  Held:  R's determinations                        
               sustained to the extent stated herein.                                 

               John M. Youngquist, for petitioners.                                   
               Allan D. Hill, for respondent.                                         

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