Rebecca Wright - Page 2




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          liable for the fraud penalty, pursuant to section 6663,1 for                
          taxable years 1992 through 1994, in the amounts of $4,242,                  
          $44,931, and $8,406, respectively.  Alternatively, respondent               
          determined that petitioners are liable for an accuracy-related              
          penalty, pursuant to section 6662(a), for the taxable years 1992            
          through 1994, in the amounts of $1,131, $11,982, and $2,242,                
          respectively.  Petitioners concede the additional income                    
          determined by respondent in the notice of deficiency and present            
          only the following issues for us to address:  (1) Whether                   
          petitioner is liable for the fraud penalty pursuant to section              
          6663 for 1992, 1993, and 1994; and (2) if the fraud penalty is              
          not applicable, whether petitioners are liable for the accuracy-            
          related penalty pursuant to section 6662(a) for 1992, 1993, and             
          1994.                                                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts are incorporated herein by reference and are           
          found as facts in the instant cases.  Petitioners resided in                
          California at the time they filed their petitions in the instant            
          cases.                                                                      

          1    Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  





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