Warren Jack Kidder and Barbara Jeanne Kidder - Page 2

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          The issues that remain for our consideration are:  (1) Whether              
          petitioners are entitled to claim a nonbusiness bad debt                    
          deduction for loans made to petitioner Barbara Jean Kidder’s                
          (Mrs. Kidder’s) son; and (2) whether petitioners are liable for a           
          late filing addition to tax for 1992 and/or an accuracy-related             
          penalty for the 1992 and/or 1993 tax year.                                  
                                  FINDINGS OF FACT1                                   
               Petitioners resided in Pebble Beach, California, at the time           
          their petition was filed in this case.  Petitioners filed a joint           
          Federal income tax return for their 1992 and 1993 taxable years.            
          With respect to their 1992 return, petitioners sought two                   
          extensions of time to file, the last of which extended the time             
          to October 15, 1993.  Petitioners’ 1992 return was executed by              
          the return preparer on October 11, 1993, and by petitioners on              
          October 14, 1993.  The date stamp placed on petitioners’ 1992               
          income tax return, which would normally show when respondent                
          received the return, is illegible.                                          
               During the taxable years, Mrs. Kidder was employed as a                
          manager and petitioner Warren J. Kidder (Mr. Kidder) was self-              
          employed as an appraiser.  Mrs. Kidder began advancing funds to             
          her son, David Bogue (Mr. Bogue), in 1983.  The advances were to            
          pay for Mr. Bogue’s personal and business obligations.  Some of             

               1 The stipulation of facts and the attached exhibits are               
          incorporated by this reference.                                             

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