Jerry L. and Valerie J. Hill - Page 1

                                 T.C. Memo. 2004-156                                  

                               UNITED STATES TAX COURT                                

                  JERRY L. HILL AND VALERIE J. HILL, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7058-03.             Filed June 30, 2004.                   

               Joe Alfred Izen, Jr., for petitioners.                                 
               Huong Duong, for respondent.                                           

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioners petitioned the Court to                      
          redetermine a $130,260 deficiency in their 1999 Federal income              
          tax and a $26,052 accuracy-related penalty under section 6662(a).           
          Following concessions, including petitioners’ concession that the           
          trust at hand (Re-Cap Trust) is disregarded for Federal income              
          tax purposes, we decide whether petitioners may deduct certain              

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