Dan E. and Susan J. Martens - Page 2




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          years in issue, and all Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
               After concessions, the issues for decision are                         
          whether petitioners are:  (1) Entitled, pursuant to section 166,            
          to a business bad debt deduction relating to 1993; (2) entitled,            
          pursuant to section 162, to a business expense deduction                    
          relating to 1994; and (3) liable, pursuant to section 6662(a),              
          for accuracy-related penalties relating to the deductions.                  
                                  FINDINGS OF FACT                                    
               Mr. Martens, during adolescence, college, and law school,              
          worked at The Stork Shop, Inc. (the Stork Shop), a maternity wear           
          retail store owned by his mother, Estele Wooden.  In 1966, she              
          gave him a joint tenancy with right of survivorship in the stock            
          of the Stork Shop.  The store was located in Oklahoma City,                 
          Oklahoma, approximately 200 miles from Dallas, Texas, where                 
          petitioners, husband and wife, have resided and worked since                
          1982.  Mr. Martens has been an attorney since 1974, and Ms.                 
          Martens was a homemaker during the years in issue.                          
               Ms. Wooden operated the Stork Shop until it ceased                     
          operations in 1993.  Mr. Martens made management decisions, and             
          Ms. Martens regularly bought apparel for and monitored inventory            
          levels at the store, but neither of them received any                       
          compensation.  Petitioners made a series of loans to the Stork              








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