Mercedes Arcia - Page 2

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          6651(a)(1) addition to tax, and a $7,075 section 6662(a) accuracy-           
          related penalty.                                                             
               All section references are to the Internal Revenue Code as in           
          effect for the year in issue, and all Rule references are to the             
          Tax Court Rules of Practice and Procedure.                                   
               These cases were consolidated for trial, briefing, and                  
          opinion.                                                                     
               The issues for decision are: (1) Whether petitioners had                
          $106,000 of unreported income in 1991; and (2) if so, then (a)               
          whether petitioner Mercedes Arcia (Mrs. Arcia) qualifies as an               
          innocent  spouse  pursuant  to  section  6013(e);  (b)  whether              
          petitioners are liable for the section 6651(a)(1) addition to tax            
          for 1991; and (c) whether petitioners are liable for the section             
          6662(a) accuracy-related penalty for 1991.                                   
                                   FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The           
          stipulation of facts and the attached exhibits are incorporated              
          herein by this reference.                                                    
               Elio and Mercedes Arcia, husband and wife, resided in Miami,            
          Florida, at the time they filed their respective petitions in these          
          cases.                                                                       
          Eduardo Macias and His Friends                                               
               Eduardo Macias, born in Cuba but living in the United States            
          at all relevant times, served time in a U.S. prison between 1983             





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