                                         T.C. Memo. 1995-481                                               


                                       UNITED STATES TAX COURT                                             


                       OLIVER Q. FOUST AND TALIETHA FOUST, Petitioners                                     
                       v. COMMISSIONER OF INTERNAL REVENUE, Respondent                                     


                  Docket No. 7864-92.                Filed October 4, 1995.                                

                  Oliver Q. Foust, pro se.                                                                 
                  Thomas M. Rohall, for respondent.                                                        


                            MEMORANDUM FINDINGS OF FACT AND OPINION                                        

                  RUWE, Judge:  Respondent determined a deficiency in                                      
            petitioners' 1988 Federal income tax of $40,558.                                               
                  The issues for decision are:  (1) Whether petitioners have                               
            substantiated the basis of their stock in Vosburg Hotels, Inc., a

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