Richard T. Stanley, Sr. and Miriam Stanley - Page 1

                                 T.C. Memo. 1999-20                                   

                               UNITED STATES TAX COURT                                

             RICHARD T. STANLEY, SR. AND MIRIAM STANLEY, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 987-97.                   Filed January 29, 1999.           

                    Held:  P has failed to establish the existence,                   
               amount, or worthlessness in the years at issue of                      
               claimed nonbusiness and business bad debts.  P has also                
               failed to substantiate itemized deductions disallowed                  
               by R.  P is liable for accuracy-related penalties for                  
               negligence under sec. 6662, I.R.C.                                     

               Robert N. Bedford and Bruce G. Kaufmann, for petitioners.              
               Charles A. Baer, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               LARO, Judge:  Richard T. and Miriam Stanley petitioned the             
          Court to redetermine 1992 through 1994 income tax deficiencies of           
          $97,474, $152,220, and $5,569, respectively, and accuracy-related           

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