Frank A. Luca and Sherry L. Luca - Page 2

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          and $53,243, respectively.2  The determined deficiencies are                  
          largely attributable to respondent’s disallowance of all                      
          deductions claimed by petitioners on Schedule C, Profit or Loss               
          From Business.3  Respondent disallowed the claimed deductions on              
          the grounds that the expenses supporting such deductions (1) were             
          not incurred or (2) if incurred, were not paid for ordinary and               
          necessary business purposes.                                                  
               We shall grant respondent’s motion to dismiss for lack of                
          prosecution, and we shall enter a decision against petitioners                
          for the stated deficiencies and penalties.  In light of our                   
          action, we consider it appropriate to explain the events in this              
               On July 14, 1997, petitioners filed their petition in this               
          case and requested that the trial be held in Phoenix, Arizona.                
          In addition to being signed by counsel for petitioners, the                   
          petition was also executed by each petitioner individually.  The              
          address for petitioners listed therein was 8502 East Sutton                   
          Drive, Scottsdale, Arizona.                                                   

               2  Respondent later revised his determination to reflect                 
          deficiencies in petitioners’ Federal income tax of $121,661 and               
          $256,860 for 1993 and 1994, respectively, and accuracy-related                
          penalties of $24,332 and $51,372, respectively.                               
               3  Respondent disallowed $314,678 and $424,993 of Schedule               
          C, Profit or Loss From Business, deductions for taxable years                 
          1993 and 1994, respectively.                                                  

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