Kenneth E. and Lois M. Edwards - Page 1

                                 T.C. Memo. 1999-52                                   

                               UNITED STATES TAX COURT                                

                   KENNETH E. AND LOIS M. EDWARDS, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 257-98.              Filed February 25, 1999.               

               Kenneth E. and Lois M. Edwards, pro sese.                              
               Jeremy L. McPherson, for respondent.                                   

                                 MEMORANDUM OPINION                                   
               GERBER, Judge:  Respondent determined a deficiency in                  
          petitioners’ 1993 Federal income tax in the amount of $83,430 and           
          a penalty under section 6662(a)1 in the amount of $16,686.  The             

               1 Unless otherwise stated, all section references are to the           
          Internal Revenue Code in effect for the taxable year in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              

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