














                                 T.C. Memo. 2002-20                                   


                               UNITED STATES TAX COURT                                


          SARAH A. BLAND-BARCLAY AND FRANCIS BARCLAY, DECEASED, Petitioners           
                                         v.                                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1014-00.            Filed January 22, 2002.                 

               Sarah A. Bland-Barclay, pro se.                                        
               Chang Ted Li, for respondent.                                          

                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  Respondent determined a                
          deficiency in petitioners’ Federal income tax for the taxable               
          year 1996 in the amount of $9,356, and an accuracy-related                  
          penalty in the amount of $1,854.  Unless otherwise indicated,               
          section references are to the Internal Revenue Code in effect for           
          the year in issue.

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