Leroy and Shirley Combs - Page 1

                                 T.C. Memo. 2001-264                                  

                               UNITED STATES TAX COURT                                

                       LEROY AND SHIRLEY COMBS, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9198-00.           Filed October 3, 2001.                   

               Leroy and Shirley Combs, pro sese.                                     
               Dale A. Zusi, for respondent.                                          

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notice dated May 24, 2000, respondent                
          determined a $298,992 deficiency, a $74,598 section 6651(a)                 
          addition to tax, and a $59,798 section 6662(a) penalty relating             
          to petitioners’ 1994 Federal income tax.  All section references            
          are to the Internal Revenue Code in effect for the year in issue.           
          The issues for decision are whether petitioners failed to report            
          income for 1994 and are liable for a section 6651 addition to               

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