David M. and Audrey J. Fugitt - Page 3

                                        - 2 -                                         
               Respondent determined a deficiency in petitioners’ Federal             
          income tax for 1999 in the amount of $8,180, as well as an                  
          accuracy-related penalty under section 6662(a) in the amount of             
          $1,636.2                                                                    
               The issues for decision are:                                           
               (1) Whether petitioners failed to report self-employment               
          income in the amount of $19,125.  We hold that they did.                    
               (2) Whether petitioners are liable for the accuracy-related            
          penalty under section 6662(a).  We hold that they are.                      
               Adjustments relating to petitioners’ earned income credit              
          and self-employment tax are purely mechanical matters, the                  
          resolution of which is dependent on our disposition of the first            
          disputed issue.                                                             
          Background                                                                  
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners resided in New Smyrna Beach, Florida, at the            
          time that their petition was filed with the Court.                          
               Petitioners are a married couple.  Petitioners have two sons           
          who were schoolage and living at home throughout the taxable year           
          in issue.                                                                   
               Prior to 1999, petitioner David M. Fugitt (Mr. Fugitt) had             
          primarily worked selling used automobiles.  During 1999, Mr.                
          Fugitt worked as a recreational vehicle salesman for Southeast RV           


               2  All amounts have been rounded.                                      





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