Clyde E. Owens and Marie W. Owens - Page 3

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               5.   Whether petitioners are liable for the accuracy-related           
          penalty for negligence or intentional disregard of the rules or             
          regulations for 1989 and 1990.  We hold that they are.                      
               Section references are to the Internal Revenue Code in                 
          effect in the years in issue.  Rule references are to the Tax               
          Court Rules of Practice and Procedure.                                      
                                I.  FINDINGS OF FACT                                  
          A.   Petitioners                                                            
               1.   Mr. and Mrs. Owens                                                
               Petitioners Clyde Eugene Owens (Mr. Owens) and Marie W.                
          Owens (Mrs. Owens) are married and lived in Tallapoosa, Georgia,            
          when they filed their petition in these cases.  They have four              
          children:  Bryan, Dawn, Elaine, and Jason.  Dawn was married and            
          lived with her husband in 1989 and 1990.                                    
               At the time of trial, Mr. Owens had been in business for 40            
          years.  He and Mrs. Owens were self-employed in 1989 and 1990.              
          They operated the Big O Truck Stop and Burger Chick, a fast food            
          restaurant described further below at paragraph I-B-4.                      
               Mr. and Mrs. Owens owned the land on which the businesses              
          were located.  They hoped to build a motel on their land.  They             
          had a sign that said they would open a motel there in 2001.  In             
          1989 and 1990, they had grapevines and had on their property what           
          they called a vineyard master house, not otherwise described in             
          the record.  The vines began to die in 1990.                                

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