Edward D. Lang and Sharon A. Lang - Page 2




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          determined in the alternative that petitioners are liable for the             
          accuracy-related penalty for negligence under section 6662 for                
          each year.                                                                    
               Petitioner1 and Donald J. Trisch (Trisch) formed a                       
          partnership called Diversified Resources and Development (DRD) in             
          the early 1980's to own rental property.  After concessions, the              
          issues for decision are:                                                      
               1.   Whether petitioner and Trisch continued to be partners              
          in DRD during the years in issue (1989-93).  We hold that they                
          did.                                                                          
               2.   Whether certain engineering income that Trisch earned               
          during the years in issue was income of the DRD partnership.  We              
          hold that it was not.  Thus, petitioners are not liable for tax               
          on that income.                                                               
               3.   Whether certain income and losses from real estate                  
          rental property owned by DRD were partnership income and losses.              
          We hold that they were.                                                       
               4.   Whether tax years 1992 and 1993 should be dismissed                 
          from this case.  We hold that they should not.                                
               5.   Whether petitioners are liable for the accuracy-related             
          penalty under section 6662 for each year.  We hold that they are              
          not.                                                                          




               1  References to petitioner are to Edward D. Lang.                       




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