Ghalardi Income Tax Education Foundation - Page 2

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             income tax of petitioner Ghalardi Income Tax Education                   
             Foundation:                                                              
                  Year      Deficiency     Penalty Sec. 6662(a)                       
                  1993      $14,334        $2,866                                     

             Unless stated otherwise, all section references are to the               
             Internal Revenue Code as in effect for the years in issue.               
             Respondent also determined the following deficiencies in,                
             addition to, and penalties with respect to the Federal                   
             income tax of William S. Webber, Jr.:                                    
                                                     Addition to Tax                  
             Year   Deficiency   Penalty Sec. 6662   Sec. 6651(a)(1)                  
             1992     $19,404    $3,881              -0-                              
             1993      27,426         5,485               $1,371                      

             These cases were consolidated for trial, briefing, and                   
             opinion by order of the Court issued pursuant to Rule                    
             141(a) of the Tax Court Rules of Practice and Procedure.                 
             In this opinion all Rule references are to the Tax Court                 
             Rules of Practice and Procedure.                                         
                  The issue for decision in this case is whether                      
             respondent properly determined the subject tax                           
             deficiencies, penalties, and addition to tax.                            

                                  FINDINGS OF FACT                                    
                  Mr. Webber filed Forms 1040, U.S. Individual Income                 
             Tax Return, for 1992 and 1993.  On each return, Mr. Webber               




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