Estate of Kenneth F. Schoeneman - Page 1

                                 T.C. Memo. 2000-161                                  

                               UNITED STATES TAX COURT                                

                     ESTATE OF KENNETH F. SCHOENEMAN, DECEASED,                       
               JOANN METZ AND JAMES J. RILEY, EXECUTORS, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15230-97.                     Filed May 18, 2000.           

               Sudhir R. Patel, for petitioners.                                      
               James Fee and Michael D. Baker, for respondent.                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notice dated April 15, 1997, respondent              
          determined deficiencies of $38,110, $38,098, and $18,119, and               
          section 6662(a) penalties of $7,622, $7,620, and $3,624, relating           
          to Kenneth Schoeneman’s 1993, 1994, and 1995 Federal income                 
          taxes, respectively.  All section references are to the Internal            
          Revenue Code in effect for the years in issue.  The executors of            

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