Marvin W. and Kathryn A. McPike - Page 4

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          for negligence or intentional disregard of the rules or                     
          regulations; (2) whether petitioners are liable for the 1984                
          addition to tax under section 6651(a)(1); (3) whether petitioners           
          are liable for the additions to tax for substantial                         
          understatement of income tax for 1983 and 1984 under section                
          6661(a); and (4) whether petitioners are liable for an increased            
          rate of interest on deficiencies attributable to tax motivated              
          transactions under section 6621(c).                                         
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and exhibits attached thereto are                  
          incorporated herein by this reference.  Petitioners resided in              
          San Bernardino, California, when their petition was filed in this           
          case.                                                                       
               Marvin McPike (petitioner) is a retired fire fighter.  He              
          was employed for 28 years as a fireman in San Bernardino and 4              
          years in Colton.  He has a high school education.  Since                    
          graduating from high school, petitioner received no further                 
          formal education, except for a few courses in fire science.                 
          Petitioner has no previous investment experience other than                 
          investing in his personal residence.                                        
               Kathryn McPike (Mrs. McPike) completed the ninth grade in              
          school.  During the years before the Court she was employed as              
          office manager and general clerk for the United Food and                    
          Commercial Workers Union.  Her responsibilities included typing,            




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