Charles E. and Jacquelyn Yates - Page 1

                                 T.C. Memo. 2001-280                                  

                               UNITED STATES TAX COURT                                

                   CHARLES E. AND JACQUELYN YATES, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 5386-00, 8504-00.        Filed October 11, 2001.           

               Bruce M. Reynolds and Ashley W. Ward, for petitioners.                 
               Michael D. Zima, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notices dated February 9 and June 23,                
          2000, respondent determined deficiencies in petitioners’ 1994,              
          1995, and 1996 Federal income taxes of $237,945, $457,955, and              
          $172,586, respectively.  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                  

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