Julius and Hanan Dibsy - Page 1

                                 T.C. Memo. 1995-477                                  


                               UNITED STATES TAX COURT                                

                       JULIUS AND HANAN DIBSY, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16466-93.               Filed October 4, 1995.              


               Julius Dibsy, pro se.                                                  
               Roy Wulf, for respondent.                                              


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               GERBER, Judge:  Respondent determined a deficiency in                  
          petitioners' 1989 Federal income tax of $34,079 and additions to            
          tax under sections 66541 and 6662(a) in the amounts of $191 and             
          $6,816, respectively.  The issues for our consideration are:  (1)           


               1 All section references are to the Internal Revenue Code in           
          effect for the taxable year under consideration, and all Rule               
          references are to this Court's Rules of Practice and Procedure,             
          unless otherwise indicated.                                                 




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