Christopher M. and Theanne K. Weil - Page 2




                                        - 2 -                                         
          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 respondent,1 we must decide the                   
          following issues:2  (1) Whether petitioners are entitled to                 
          deductions for interest that they paid with respect to delinquent           
          Federal income taxes for 1984, 1985, 1986, 1987, and 1993; (2)              
          whether petitioners are liable for the addition to tax under                
          section 6651(a) for 1995; and (3) whether petitioners are liable            
          for an accuracy-related penalty under section 6662(a) for 1996.             
                                     Background                                       
               The parties submitted the instant case fully stipulated                
          pursuant to Rule 122.  The stipulated facts are incorporated                
          herein by reference and are found as facts in the instant case.             
          Petitioners resided in Dallas, Texas, when they filed their                 
          petition.                                                                   





               1Respondent conceded the following items:  (1) The                     
          adjustment in the notice of deficiency of $15,954 for alleged               
          unreported interest income for 1995; (2) $26,136 of the total               
          adjustment in the notice of deficiency for itemized deductions              
          for 1996; and (3) the accuracy-related penalty under sec. 6662 in           
          the amount of $12,968 for 1995.                                             
               2Certain computational issues also remain for 1995,                    
          resolution of which flows automatically from our resolution of              
          the determinations in the notice that we address herein.                    




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