














                                  T.C. Memo. 2002-6                                   


                               UNITED STATES TAX COURT                                


                  ROBERT GRIFFIN AND JULIA GRIFFIN, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7315-00.                  Filed January 8, 2002.            

               James Allen Brown, for petitioners.                                    
               H. Elizabeth Downs, for respondent.                                    


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               THORNTON, Judge:  For taxable years 1995 and 1996,                     
          respondent determined deficiencies of $47,775 and $53,144,                  
          respectively, in petitioners’ Federal income taxes.  The sole               
          issue for decision is whether petitioners are entitled to deduct            
          as real property taxes, or as business expenses, amounts paid by            
          petitioner husband (petitioner) with respect to properties owned

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