Frederick W. and Candace J. Tiley - Page 1

                                 T.C. Memo. 2003-132                                  

                               UNITED STATES TAX COURT                                

                  FREDERICK W. AND CANDACE J. TILEY, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1402-02.               Filed May 8, 2003.                   

               Frederick W. and Candace J. Tiley, pro sese.                           
               Kelley Blaine and Robert V. Boeshaar, for respondent.                  

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COHEN, Judge:  Respondent determined a deficiency of $6,409            
          in petitioners’ Federal income tax for 1998 and a penalty of                
          $1,281.80 under section 6662(a).  Unless otherwise indicated, all           
          section references are to the Internal Revenue Code in effect for           
          the year in issue.  The issue for decision is whether petitioners           
          are liable for the accuracy-related penalty.                                

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