Michael L. and Susan Barnard - Page 2




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          1989.  Respondent determined deficiencies of $11,253, $15,996,              
          and $14,689 for the respective years.  Respondent also determined           
          that petitioners were liable for an $8,440 addition to their 1987           
          tax under section 6653(b)(1)(A), an $11,997 addition to their               
          1988 tax under section 6653(b)(1), and an $11,017 penalty for               
          fraud as to 1989.  Respondent also determined that petitioners              
          were liable for a time-sensitive addition to their 1987 tax under           
          section 6653(b)(1)(B).                                                      
               We must decide whether petitioners are liable for the                  
          deficiencies, additions to tax, and penalty.  We hold they are              
          liable for the deficiencies to the extent stated herein and that            
          they are not liable for any of the additions to tax or the                  
          penalty.  Unless otherwise indicated, section references are to             
          the Internal Revenue Code applicable to the relevant years.  Rule           
          references are to the Tax Court Rules of Practice and Procedure.            
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated.  We incorporate herein by             
          this reference the parties’ stipulation of facts and the exhibits           
          submitted therewith.  We find the stipulated facts accordingly.             
          Petitioners resided in Charlevoix, Michigan (Charlevoix), when              
          their petition was filed.  They filed joint 1987, 1988, and 1989            
          Federal income tax returns.                                                 
               Michael Barnard (Mr. Barnard) grew up in East Jordan,                  
          Michigan.  Upon graduating from high school, he attended the                






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