Franklin D. and Sandra M. Terrell - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               NIMS, Judge: Respondent determined deficiencies, additions             
          to tax, and accuracy-related penalties for 1991, 1992, and 1993             
          with respect to petitioners' Federal income taxes as follows:               
                                   Addition to tax       Penalty                      
          Year      Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)                   
          1991      $23,617        $5,345              $4,723                         
          1992      28,454         6,597               5,691                          
          1993      32,748         1,566               6,550                          
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the years in            
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.  All dollar amounts are rounded to the              
          nearest dollar.                                                             
               After concessions by both parties, the remaining issues for            
          decision are: (1) Whether petitioners are liable for the                    
          additions to tax under section 6651(a)(1) for failure to timely             
          file their 1991, 1992, and 1993 Federal income tax returns; and             
          (2) whether petitioners are liable for the accuracy-related                 
          penalty under section 6662(a).                                              
                                  FINDINGS OF FACT                                    
               At the time the petition was filed, petitioners resided in             
          Los Angeles, California.  During the years in issue, petitioner             
          Franklin Terrell was a general contractor engaged in the                    
          construction business.                                                      

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