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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.
After concessions, the issues for decision are:
(1) Whether Crabtree Investments underreported its gross
income for 1992, 1993, and 1994; (2) if Crabtree
Investments underreported income, whether petitioners Jerry
L. and Eddie L. Crabtree each received constructive
dividends from the corporation in 1992, 1993, and 1994 of
one-half of the gross income that went unreported; (3)
whether each petitioner is liable for the fraud penalty
under section 6663 for the years in issue; and (4) if the
fraud penalty is not applicable, whether each petitioner
is liable for the accuracy-related penalty under section
6662(a) attributable to negligence or disregard of rules
or regulations. Petitioners do not contend that the period
of limitations on assessments set forth in section 6501
applies in these cases.
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. At the time of
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