G. Kierstead Family Holdings Trust, et al. - Page 2

          trial, the parties stipulated that there are no deficiencies in             
          Federal income tax or penalties due from petitioners G. Kierstead           
          Family Holdings Trust or G. Kierstead Family Trust.  Respondent             
          determined Federal income tax deficiencies and penalties for                
          petitioners2 Glenn and Carol Kierstead as follows3:                         
               Year at Issue       Deficiency     Sec. 6662(a)                        
               2001                $40,410        $8,080                              
               2002                38,165          7,633                              
               2003                66,179         13,235                              
               The parties filed a stipulation of settled issues necessary            
          for a determination of the amount of the liability for the years            
          in question, other than applicable penalties.  Accordingly, the             
          only issue to be determined is whether petitioners Glenn and                
          Carol Kierstead are liable for accuracy-related penalties under             
          section 6662(a) for 2001, 2002, and 2003 (years at issue).4                 

                                  FINDINGS OF FACT                                    

               2Unless otherwise indicated, reference to “petitioners”                
          shall mean petitioners Glenn E. and Carol L. Kierstead as                   
               3Unless otherwise indicated, all section references are to             
          the Internal Revenue Code, as amended.  All Rule references are             
          to the Tax Court Rules of Practice and Procedure, unless                    
          otherwise indicated.                                                        
               4The parties stipulated that petitioners are liable for                
          accuracy-related penalties under sec. 6662(a) for 2001, 2002, and           
          2003 for the portion of their deficiencies allocable to their               
          failure to include interest income in the amounts of $8,633,                
          $8,465, and $8,174, respectively.                                           

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