Joseph P. and Marilyn Schneller - Page 3

          income in 1990.  We hold that they did.                                            
                (3) Whether petitioners are liable for the accuracy-related                  
          penalty pursuant to section 6662.  We hold that they are.                          
                All section references are to the Internal Revenue Code in                   
          effect for the year under consideration.  All Rule references are                  
          to the Tax Court Rules of Practice and Procedure.                                  
                                     FINDINGS OF FACT                                        
                Some of the facts have been stipulated and are so found.  The                
          stipulation of facts and the attached exhibits are incorporated                    
          herein by this reference.                                                          
                Petitioners, husband and wife, resided in Bowling Green,                     
          Kentucky, at the time they filed their petition.  They timely filed                
          a joint Federal income tax return for 1990, the year under                         
                Petitioners own all the stock of Land Air Delivery, Inc.                     
          (Delivery or the corporation), an air freight motor carrier that                   
          engages in the pickup and delivery of packages for overnight                       
          carriers.  Joseph P. Schneller (petitioner) started Delivery in                    
          1963 with a single truck.  At its peak, Delivery operated 250                      
          trucks and delivered freight nationwide.  For all periods relevant                 
          to this case, petitioner was the president and Mrs. Schneller was                  
          the secretary of Delivery.                                                         
                Delivery has been a subchapter C corporation from its                        
          inception.  Corporate income tax returns (Forms 1120) were filed                   

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