Albert R. Cujas, Jr., & Susan W. Cujas - Page 3

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                  5.  Whether petitioners, pursuant to section 6654(a), are                              
            liable for additions to tax for failure to make estimated tax                                
            payments.  We hold that they are liable to the extent provided                               
                  6.  Whether petitioners have asserted frivolous and                                    
            groundless arguments that warrant the imposition of a penalty                                
            pursuant to section 6673.  We hold that a penalty is not                                     
                                          FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are so found.  At                           
            the time their joint petition was filed, petitioners' mailing                                
            address was in Kernersville, North Carolina.                                                 
                  During the years in issue, Albert Cujas was married to Susan                           
            Cujas and was self-employed as a physical therapist.  Petitioners                            
            filed a joint Federal income tax return for 1991, but did not                                
            file returns for 1992 or 1993.  The Internal Revenue Service                                 
            audited petitioners' 1991 return, and Agent Jerry Gardner was                                
            assigned to the case.  He notified petitioners in writing that                               
            their 1991 return was being audited.  In this correspondence, he                             
            asked petitioners to meet with him and to provide records                                    
            relating to their 1991 income and expenses.  Petitioners did not                             
            comply with Agent Gardner's requests.                                                        
                  After Agent Gardner had completed his audit of petitioners'                            
            1991 return, he began an audit relating to petitioners' 1992 and                             

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