J. Michael Joly and Bonnie B. Joly, Jody Steven Joly, and David Andrew Joly - Page 2

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               Respondent determined deficiencies in petitioners' Federal             
          income taxes and accuracy-related penalties for the years as                
          follows:                                                                    
          Petitioners J. Michael Joly and Bonnie B. Joly                              
                                             Accuracy-Related                         
                    Year      Deficiency         Penalty                              
                    1992      $5,478              $1,096                              
                    1993      3,464               693                                 
                    1994      1,951               390                                 
          Petitioner Jody Steven Joly                                                 
                    Year                       Deficiency                             
                    1993                     $1,020                                   
                    1994                     1,583                                    
          Petitioner David Andrew Joly                                                
                    Year                       Deficiency                             
                    1992                     $2,143                                   
               After concessions, the issues remaining for decision are:              
          (1) Whether certain amounts paid to or on behalf of J. Michael              
          Joly and Jody Steven Joly by J. Michael Joly, Inc. constitute               
          employee wages; (2) the correct method of computing the amounts             
          of the losses and gains that J. Michael Joly, Jody Steven Joly,             
          and David Andrew Joly must recognize with respect to their                  
          J. Michael Joly, Inc. stock; and (3) whether J. Michael Joly and            
          Bonnie B. Joly are liable for the section 6662(a) accuracy-                 
          related penalties.                                                          
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             




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