Betty June Dykstra and Pieter Dykstra - Page 3

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          6651(a)(1) for 1994 and 1995;1 and (6) whether petitioners are              
          liable for an addition to tax for failing to make estimated                 
          Federal income tax payments pursuant to section 6654 for 1995.              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, supplemental stipulation of facts, and            
          attached exhibits are incorporated herein by this reference.  At            
          the time they filed their petition, petitioners resided in                  
          Tulare, California.                                                         
               Petitioners filed their 1994 Federal income tax return                 
          (return) on September 11, 1995.  Petitioners did not file a                 
          return for 1995.                                                            
          Payments from Conoco                                                        
               Prior to and during the years in issue, petitioner Pieter              
          Dykstra (Mr. Dykstra) held an interest in an oil lease from                 
          Conoco.  During this time, Mr. Dykstra was obligated to pay                 
          monthly working costs to Lauck and Associates (Lauck), the                  
          operator of the well.  When Mr. Dykstra failed to make such                 
          payments, Lauck obtained a mechanic's lien against Mr. Dykstra's            
          interest and notified Conoco that all future royalty payments               
          should be made to Lauck.                                                    

               1 For 1995, respondent asserted an addition to tax pursuant            
          to sec. 6651(a)(1) against Mrs. Dykstra in the alternative to an            
          addition to tax pursuant to sec. 6651(f).                                   

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