B. Albert and Betty M. Holowinski - Page 2

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               Respondent determined deficiencies in petitioners' Federal             
          income taxes and accuracy-related penalties as follows:                     
                    Years       Deficiencies      Sec. 6662(a) Penalties              
                    1992           $1,905              $381                           
                    1993           3,570               714                            
                    1994           2,029               406                            
               The issues are:  (1) Whether petitioners' antique glassware            
          sales activity was engaged in for profit within the meaning of              
          section 183, and (2) whether petitioners are liable for the                 
          accuracy-related penalties pursuant to section 6662(a).                     
               Petitioners resided in Littleton, Colorado, at the time they           
          filed their petition.  The facts may be summarized as follows.              
               Petitioner Betty M. Holowinski obtained a high school degree           
          and attended 2 years of college where she studied political                 
          science.  Petitioner B. Albert Holowinski served in the United              
          States military for many years and, after his military                      
          retirement, worked in the aerospace industry.  During his                   
          military service he obtained a bachelor's degree in business and            
          a master's degree in urban affairs.                                         
               In 1992, both petitioners had retired.  Early that year,               
          Mrs. Holowinski became interested in buying and selling Victorian           
          glassware.  She thought they could make money and that they would           
          have fun traveling around to various antique shops and flea                 
          markets looking for the glass.  To gain some background knowledge           

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