Peter and Mary Possas - Page 16




                                       - 15 -                                         
               As indicated above, petitioners possessed facts sufficient             
          to allow them to estimate their income and expenses with respect            
          to the hairdressing activity.  Petitioners failed to make any               
          attempt to calculate their income and expenses for 1996.                    
          Accordingly, they are liable for the section 6662(a) accuracy-              
          related penalty for 1996.                                                   
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          



























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