Charles and Martha McHan - Page 1

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                                 T.C. Memo. 1996-12                                   


                               UNITED STATES TAX COURT                                


                      CHARLES AND MARTHA McHAN, Petitioners v.                        
                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       


               Docket No. 550-92.                Filed January 22, 1996.              


               R. Walton Davis III, for petitioner Martha McHan.                      
               Charles McHan, pro se.                                                 
               Eric B. Jorgensen, for respondent.                                     


                                 MEMORANDUM OPINION                                   
               PARR, Judge:  This case is presently before the Court on               
          petitioner Charles McHan's and petitioner Martha McHan's                    
          (hereinafter sometimes referred to as Charles and Martha,                   
          respectively) separately filed motions for summary judgment