Richard R. Pelham and Paula A. Pelham - Page 2




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          Richard R. and Paula A. Pelham                                              
          Docket No. 18687-99                                                         
                                             Penalty                                  
                   Year    Deficiency     Sec. 6662(a)                                
                   1996       $4,761           $952                                   
                   1997       11,050      2,210                                       
          RRP Trust, Richard R. Pelham, Trustee                                       
          Docket No. 18688-99                                                         
                                             Penalty                                  
                   Year    Deficiency     Sec. 6662(a)                                
                   1996      $12,297         $2,459                                   
                   1997       36,558          7,312                                   

               Unless otherwise indicated, 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.  After concessions by the parties, the issue remaining           
          for decision is whether petitioner RRP Trust (the trust) should             
          be disregarded for Federal income tax purposes and the income and           
          expense from the business operations of Lake Lock & Key                     
          attributed to petitioners Richard R. Pelham and Paula A. Pelham             
          (the Pelhams).                                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
               Richard R. Pelham (Richard Pelham) and Paula A. Pelham                 
          (Paula Pelham), husband and wife, resided in Humble, Texas, at              







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