Marvin W. and Kathryn A. McPike - Page 1

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                                 T.C. Memo. 1996-46                                   


                               UNITED STATES TAX COURT                                


                   MARVIN W. AND KATHRYN A. MCPIKE, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16752-87.        Filed February 12, 1996.                   


               Marvin W. and Kathryn A. McPike, pro se.                               

               Debra Bowe, for respondent.                                            


                       MEMORANDUM FINDINGS of FACT and OPINION                        

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Larry L. Nameroff pursuant to section 7443A(b)(4) and Rules           
          180, 181, and 183.1  The Court agrees with and adopts the opinion           


          1         All section references are to the Internal Revenue Code           
          in effect for the years in issue.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.