David Carkhuff and Tonja Carkhuff - Page 1

                                 T.C. Memo. 1995-565                                  

                               UNITED STATES TAX COURT                                

                  DAVID CARKHUFF AND TONJA CARKHUFF, Petitioners v.                   
                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 19773-94.             Filed November 28, 1995.              

               David Carkhuff and Tonja Carkhuff, pro sese.                           
               Robert E. Cudlip, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               PARR, Judge:  This matter is before the Court on                       
          respondent's Motion for Summary Judgment, filed October 6, 1995,            
          pursuant to Rule 121.1                                                      

               All Rule references are to the Tax Court Rules of Practice             
          and Procedure, and all section references are to the Internal               
          Revenue Code in effect for the taxable years in issue, unless               
          otherwise indicated.                                                        

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