Mark and Helen Thomson - Page 1

                                 T.C. Memo. 1999-371                                  

                               UNITED STATES TAX COURT                                

                       MARK AND HELEN THOMSON, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23704-97.                 Filed November 8, 1999.           

               Conrad D. Carnes, for petitioners.                                     
               Jean Bass and Nguyen-Hong K. Hoang, for respondent.                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               CHIECHI, Judge:  Respondent determined the following defi-             
          ciencies in, and accuracy-related penalties under section                   
          6662(a)1 on, petitioners' Federal income tax:                               

               1All section references are to the Internal Revenue Code               
          (Code) in effect for the years at issue.  All Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           

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