Curtis R. and Lynn Bitker - Page 43

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          incorrect treatment of the interest paid on those mortgages was due         
          to Mr. Mostoller’s mistakes.  Accordingly, we hold that petitioners         
          are liable for the section 6662(a) accuracy-related penalty with            
          regard to the increases in income tax and self-employment tax               
          resulting from the disallowance of the deduction claimed by the             
          Bitker partnership for interest on petitioners’ debt.                       
               To reflect the foregoing and concessions by the parties,               

                                                  Decisions will be entered           
                                             under Rule 155.                          

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