Hugh D. Summers and Teresa E. Summers - Page 3

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          Court challenging the notice of deficiency.  On September 26,               
          1997, pursuant to an agreement between the parties, we entered a            
          decision holding that petitioners were liable for a penalty in              
          the amount of $13,858 pursuant to section 6662(a) for 1989 and              
          that petitioners owed an unpaid prior assessment of $69,289 for             
          1989.  See Summers v. Commissioner, docket No. 17005-95.  On                
          November 24, 1997, respondent assessed petitioners the section              
          6662(a) penalty in the amount of $13,858 for petitioners’ 1989              
          taxable year.                                                               
               Litigation Involving Petitioners and Commonwealth Land Title           
          Insurance Company                                                           
               During July 1997, respondent filed a Notice of Federal Tax             
          Lien (NFTL) against petitioners in Berks and Montgomery Counties,           
          Pennsylvania, relating to petitioners’ unpaid tax liabilities for           
          1982 through 1990.  Petitioners’ surname, however, was misspelled           
          as “Hugh D. & Teresa E. Summer” on the NFTL filed in Montgomery             
          County, Pennsylvania.                                                       
               On July 31, 1997, Mr. Summers sold two properties to                   
          Leemilt’s Petroleum, Inc.:  (1) 270 W. Greenwich Street, Reading,           
          Berks County, Pennsylvania (the Berks County Property); and (2)             
          Buckert Road and Keim Street, Lower Pottsgrove Township,                    
          Montgomery County, Pennsylvania (the Montgomery County Property).           
          Commonwealth Land Title Insurance Company (Commonwealth) insured            
          the title on both properties for the purchaser, Leemilt’s                   
          Petroleum, Inc., and settlement on both properties was on                   





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