Lewis Peter and Judy Hasty Larson - Page 2




                                        - 2 -                                         
          $1,264, respectively.                                                       
               The only issue remaining for decision is whether petitioners           
          are liable for 1999 for the accuracy-related penalty under                  
          section 6662(a).  We hold that they are.                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.2              
               At the time the petition was filed, petitioners, who are               
          married, resided in Annapolis, Maryland.                                    
               During 1999, Ms. Larson was a homemaker.  Sometime during              
          1999, Ms. Larson also worked for Calvary United Methodist Church,           
          for which she received wages of $175.                                       
               Since at least 1995, Mr. Larson has worked for various                 
          startup companies as a nonemployee and/or an employee.  During              
          1999, Mr. Larson worked for Telepad Corporation (Telepad), Data             
          Search Inc. (Data Search), and Windermere Information Technology            
          Systems (Windermere).  During that year, Telepad paid Mr. Larson            
          $10,000 in wages that it reported in Form W-2, Wage and Tax                 


               2On Sept. 9, 2002, the date of the trial herein, petitioner            
          Judy Hasty Larson (Ms. Larson) and respondent’s counsel signed              
          the stipulation of facts in this case.  Petitioner Lewis Peter              
          Larson (Mr. Larson) was in California on that day and did not               
          sign the stipulation of facts or appear at trial.  Although Mr.             
          Larson did not appear at trial, Ms. Larson informed the Court               
          that Mr. Larson had authorized her to speak for both of them at             
          trial, and the Court allowed her to do so.  Mr. Larson signed the           
          brief that petitioners filed in this case for himself as well as            
          for Ms. Larson.                                                             







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