James and Margarette McMahan - Page 1

                                 T.C. Memo. 2001-191                                  

                               UNITED STATES TAX COURT                                

                    JAMES AND MARGARETTE MCMAHAN, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14282-99L.                   Filed July 25, 2001.           

               Joyce Griggs, for petitioners.                                         
               Ross M. Greenberg, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  The issues for decision are whether                     
          respondent obtained verification of Federal income tax                      
          assessments and whether petitioners are liable for a section                
          6673(a)(1) penalty.  All section references are to the Internal             
          Revenue Code as amended.                                                    

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