John G. and Janice E. Parker - Page 2




                                        - 2 -                                         
                                                                                     
                                             Accuracy-Related Penalty                 
                    Year      Deficiency     Sec. 6662(a)                             
                    1994      $21,603        $4,321                                   
                    1995        20,881       4,176                                    
                    1996      18,608              3,722                               

               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.                                                                  
               References to petitioner in the singular are to John G.                
          Parker.                                                                     
               The primary issue for decision is whether significant                  
          expenses that petitioner incurred in purchasing, building,                  
          improving, and flying airplanes were incurred by petitioner in an           
          activity engaged in for profit.                                             

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petition was filed, petitioners resided in             
          Reno, Nevada.                                                               
               Since the age of 16, petitioner has been a licensed airplane           
          pilot.  While in the U.S. Air Force, petitioner earned a degree             
          in aeronautical engineering from the Air Force Institute of                 
          Technology.  Upon leaving the Air Force in 1965, petitioner                 
          became a full-time pilot for American Airlines (American) where             







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