Joseph A. and Sari F. Deihl - Page 3

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               (4) whether petitioners are liable for the section 6662                
          accuracy-related penalty for 1996, 1997, and 1998.1                         
          Certain additional adjustments, e.g., to itemized deductions, are           
          computational in nature and will be resolved by our holdings on             
          the foregoing issues.                                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.  To facilitate disposition           
          of the above issues, we shall first set forth general findings of           
          fact and then, where appropriate, make additional findings in               
          conjunction with our analysis of and opinion on discrete issues.            
               Petitioners Joseph A. and Sari F. Deihl (individually                  
          referred to as Mr. Deihl and Mrs. Deihl, respectively) are                  
          husband and wife.  During the years in issue and at the time the            
          petitions were filed in these cases, petitioners resided at 4627            
          East Foothill Drive, Paradise Valley, Arizona 85253.  Petitioners           
          have two children, Joseph Deihl II (Joe II) and William Deihl               
          (Bill).  During the years in issue, Joe II was married to Kim,              
          and Bill was married to Denyse.  Petitioners also have several              
          grandchildren.                                                              



               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code in effect for the years in issue, and Rule            
          references are to the Tax Court Rules of Practice and Procedure.            




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