Dale C. and Jacqueline L. Holt - Page 1

          T.C. Memo. 1999-348                                                          

                               UNITED STATES TAX COURT                                 

                   DALE C. AND JACQUELINE L. HOLT, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 187-98.              Filed October 20, 1999.                 
               Stephen D. Willey, for petitioner.                                      
               James F. Prothro, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                         
               PAJAK, Special Trial Judge:  Respondent determined a                    
          deficiency in petitioners' Federal income tax in the amount of               
          $6,748, together with an accuracy-related penalty under section              
          6662(a) in the amount of $1,350, for the taxable year 1995.  All             
          section references are to the Internal Revenue Code in effect for            
          the year in issue.                                                           
               On brief, respondent conceded that petitioners are not                  
          liable for the accuracy-related penalty.  Therefore, the only                

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