R. George and Penney Gregersen - Page 1

                                  T.C. Memo. 2000-325                                    

                                UNITED STATES TAX COURT                                  

                    R. GEORGE AND PENNEY GREGERSEN, Petitioners v.                       
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                        

               Docket No. 18076-97.                 Filed October 19, 2000.              

               John M. Bradley and Thomas R. Barton, for petitioners.                    
               Mark H. Howard, for respondent.                                           

                        MEMORANDUM FINDINGS OF FACT AND OPINION                          

               FOLEY, Judge:  By notice dated June 13, 1997, respondent                  
          determined a deficiency of $18,504 and a section 6662 accuracy-                
          related penalty of $3,701 relating to petitioners’ 1994 Federal                
          income taxes.  All section references are to the Internal Revenue              
          Code in effect for the year in issue, and all Rule references are              
          to the Tax Court Rules of Practice and Procedure.                              

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