Tom and Brenda Kelly - Page 5

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               Accordingly, we hold that the amounts of petitioners'                  
          deficiency in Federal income tax for 1993 and liability for the             
          section 6662(a) accuracy-penalty are equal to the amounts agreed            
          to by the parties.  See supra note 2.                                       
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          


































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