Patrick G. & Valerie V. O'Malley - Page 2




                                        - 2 -                                         
                                              Accuracy-Related Penalty                
                Year         Deficiency       Under Sec. 6662(a)                      
                1999          $16,654                $3,331.00                        
                2000          32,677                 3,517.20                         
               The issues remaining for decision are:                                 
               (1) Did petitioners sell certain property on December 2,               
          1999, for $318,000?  We hold that they did.                                 
               (2) Did petitioners sell certain property on June 14, 2000,            
          for $225,000?  We hold that they did not.                                   
               (3) Are petitioners liable for each of their taxable years             
          1999 and 2000 for the accuracy-related penalty under section                
          6662(a)?  We hold that they are for 1999 and that they are not              
          for 2000.                                                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found                
          except as stated herein.                                                    
               Petitioners resided in Crownsville, Maryland, at the time              
          they filed the petition in this case.                                       
               In 1981, petitioner Patrick G. O’Malley (Mr. O’Malley)                 
          received a bachelor of science degree in accounting from the                
          University of Maryland.  After graduating from college, Mr.                 
          O’Malley worked for one year for Price Waterhouse.  Shortly after           
          leaving Price Waterhouse, Mr. O’Malley held various jobs in the             
          food service industry.  During 1999 and 2000, the years at issue,           
          Mr. O’Malley operated various businesses, including a consulting            







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