T.C. Memo. 1999-223
UNITED STATES TAX COURT
ALTON M. TOWLES, JR., AND ESTATE OF BARBARA D. TOWLES, DECEASED,
ALTON M. TOWLES, PERSONAL REPRESENTATIVE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3889-98. Filed July 6, 1999.
B. Gray Gibbs, for petitioners.
Monica Howland and J. Scott Simpson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following de-
ficiencies in, and accuracy-related penalties under section
6662(a)1 on, petitioners' Federal income tax (tax):
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
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