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did, whether this amount is subject to self-employment tax.
We hold they did, and it is.
3. Whether petitioners are liable for the additions to tax
for substantial understatements determined by respondent under
section 6661. We hold they are.
4. Whether Mrs. Sparrow is liable for the additions to her
1986 and 1988 taxes for delinquency determined by respondent
under section 6651(a)(1). We hold she is.
5. Whether Mr. Sparrow is liable for the additions to tax
for fraud determined by respondent under section 6653(b). We
hold he is not.
6. Whether petitioners are liable for the increased rate of
interest determined by respondent under section 6621(c) for
substantial underpayments attributable to tax motivated
transactions. We hold they are not.
Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the taxable years in issue.
Rule references are to the Tax Court Rules of Practice and
Procedure. Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT1
Petitioners resided in St. George, Utah, when they
petitioned the Court. They filed a 1986 Form 1040, U.S.
1 Some of the facts have been stipulated and are so found.
The stipulations and attached exhibits are incorporated herein by
this reference.
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