Linda D. Fason - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               NIMS, Judge: Respondent determined a Federal income tax                
          deficiency for petitioner’s 1994 taxable year in the amount of              
          $5,846.  Respondent also determined a civil fraud penalty of                
          $4,385 for 1994, pursuant to section 6663.                                  
               The issues for decision are as follows:                                
               (1) Whether petitioner has established entitlement to                  
          deductions claimed for medical expenses, charitable                         
          contributions, casualty losses, and employee business or                    
          miscellaneous expenses; and                                                 
               (2) whether petitioner is liable for the section 6663 civil            
          fraud penalty or, in the alternative, the section 6662(a)                   
          accuracy-related penalty.                                                   
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the year in             
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations filed by the parties, with accompanying                    
          exhibits, are incorporated herein by this reference.                        
               Linda D. Fason resided in Lynwood, California, at the time             
          of filing her petition in this case.  On her 1994 income tax                
          return, petitioner reported having incurred, and took                       

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