John K. Jorman, Jr. and Audrey Jorman - Page 2

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          in the amount of $6,339 and an accuracy-related penalty under               
          section 6662(a) in the amount of $1,268.                                    
               After concessions by the parties, the issues for decision              
          are:  (1) Whether petitioners are entitled to an itemized                   
          deduction for moving expenses; (2) whether John K. Jorman was               
          engaged in a trade or business related to the real estate                   
          industry during the year 1991 so as to allow for deductions under           
          section 162(a); and (3) whether petitioners negligently filed               
          their 1991 Federal income tax return so as to render them liable            
          for the accuracy-related penalty imposed by section 6662(a).                
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits attached thereto are              
          incorporated herein by this reference.  During the year in issue,           
          petitioners were husband and wife and filed a joint Federal                 
          income tax return.  At the time that the petition was filed,                
          John K. Jorman resided in Plainfield, Indiana, and Audrey Jorman            
          resided in Indianapolis, Indiana.  References to petitioner are             
          to John K. Jorman.                                                          
                                  FINDINGS OF FACT                                    
               During the year in issue, petitioner was employed as a                 
          customer service supervisor with PSI Energy, Inc. (PSI).                    
          Petitioner began his employment with PSI on March 30, 1990, in              
          Bloomington, Indiana.  When he started with PSI he was living in            
          Indianapolis, Indiana.  He moved to an apartment in Bloomington             
          sometime in May or June of 1990.  Toward the end of 1990,                   

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