Hugh Wilkinson and Evelyn Wilkinson - Page 22

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          was no deficiency for 1988, and the 1989 deficiency was a mere               
          $29.  To meet the aforementioned definition, the understatement              
          must exceed $500, and it does not.                                           
               We find that Mrs. Wilkinson is jointly and severally liable             
          for the deficiency and for the additions to tax pursuant to                  
          sections 6651(a)(1) and 6654.                                                
               We have considered all arguments made by the parties for                
          holdings contrary to those set forth above, and, to the extent               
          not discussed above, find them to be unpersuasive, irrelevant, or            
          without merit.                                                               
               To reflect the foregoing,                                               
                                                   Decision will be                    
                                              entered for respondent in the            
                                              amount of the deficiency and             
                                              the additions to tax under               
                                              sections 6651(a) and 6654.               

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