Estate of Alton Bean - Page 1
















                                       T.C. Memo. 2000-355                                             


                                     UNITED STATES TAX COURT                                           


            ESTATE OF ALTON BEAN, DECEASED, GARY A. BEAN, ADMINISTRATOR, AND                           
                                   MABLE BEAN, Petitioners v.                                          
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   
             GARY A. BEAN AND CYNTHIA BEAN, Petitioners v. COMMISSIONER OF                             
                                  INTERNAL REVENUE, Respondent                                         

                  Docket Nos. 5228-99, 5229-99.       Filed November 15, 2000.                         

                  James Allen Brown, for petitioners.                                                  
                  Brian A. Smith, for respondent.                                                      


                           MEMORANDUM FINDINGS OF FACT AND OPINION                                     

                  SWIFT, Judge:  These cases were consolidated for trial,                              
            briefing, and opinion.  For years 1987 through 1992, respondent                            
            determined deficiencies in petitioners' Federal income taxes and                           
            accuracy-related penalties as follows:                                                     







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