Prindle International Marketing, UBO, Keyus Group, Trustee - Page 3

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               5.   Whether petitioners Roland and Virginia Fox are liable            
          for self-employment tax of $10,658 for 1992 and $11,057 for 1993.           
          We hold that they are.                                                      
               6.   Whether petitioners Roland and Virginia Fox are liable            
          for the addition to tax for failure to file under section 6651              
          for 1993 and the accuracy-related penalty for negligence under              
          section 6662(a) for 1989, 1992, and 1993.  We hold that they are.           
               7.   Whether petitioner Prindle International Marketing is             
          liable for the addition to tax for failure to file under section            
          6651 for 1992 and 1993.  We hold that it is not.                            
               Section references are to the Internal Revenue Code in                 
          effect for the years in issue.  Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      
                                 FINDINGS OF FACT                                     
          A.   Roland and Virginia Fox                                                
               Roland and Virginia Fox (Mr. and Mrs. Fox) were married in             
          1980 and lived in Spokane, Washington, when they filed their                
          petition.  They each have three children from prior marriages.              
               Mr. Fox joined the U.S. Air Force in 1952.  He retired in              
          1972.  He received about $22,000 in military retirement pay per             
          year in 1992 and 1993.  He and his family moved to Spokane,                 
          Washington, in November 1973.  There he earned a bachelor of arts           
          degree in Russian history.  He also enrolled in a graduate                  
          business administration program at Eastern Washington University,           
          where he took one tax course.  He attended a school for insurance           




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