Thomas C. Sandoval, Jr. and Bobbie J. Sandoval - Page 3

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          contend.  We hold that petitioner placed the vehicles in service            
          when he bought them for his business.                                       
               5.   Whether petitioners may deduct depreciation for their             
          business property in an amount greater than respondent allowed.             
          We hold that they may not.                                                  
               6.   Whether petitioners may claim net operating loss                  
          carrybacks or carryforwards or investment tax credit                        
          carryforwards for the years in issue.  We hold that they may not.           
               7.  Whether petitioners are liable for an addition to tax              
          under section 6651 for failure to timely file their Federal                 
          income tax returns for the years in issue.  We hold that they               
               8.  Whether petitioners are liable for additions to tax for            
          substantial understatement of income tax under section 6661 for             
          1985 and 1987 and for accuracy-related penalties for substantial            
          understatement of tax under section 6662(b)(2) and (d) for 1989             
          and 1990.  We hold that they are for the years they substantially           
          underpaid tax.                                                              
               References to petitioner are to Thomas C. Sandoval, Jr.                
          Section references are to the Internal Revenue Code in effect               
          during the years in issue.  Unless otherwise noted, Rule                    
          references are to the Tax Court Rules of Practice and Procedure.            

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