                                 T.C. Memo. 1995-467                                  


                               UNITED STATES TAX COURT                                


                 JOSEPH D. WILKINS AND MARY WILKINS, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8129-93.                   Filed October 2, 1995.           


               Joseph D. Wilkins, pro se.                                             
               Jerome F. Warner, for respondent.                                      


                                 MEMORANDUM OPINION                                   

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge John J. Pajak pursuant to section 7443A(b)(4) of the Code             
          and Rules 180, 181, and 183.  Unless otherwise indicated, all               
          section numbers refer to the Internal Revenue Code for the

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