Steven M. and Michele E. Grow - Page 1

                                         T.C. Memo. 1995-594                                               

                                       UNITED STATES TAX COURT                                             

                           STEVEN M. AND MICHELE E. GROW, Petitioners                                      
                       v. COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 20185-94.             Filed December 14, 1995.                                

                  Steven M. and Michele E. Grow, pro se.                                                   
                  Amy Dyar Seals, for respondent.                                                          

                            MEMORANDUM FINDINGS OF FACT AND OPINION                                        

                  POWELL, Special Trial Judge:  This case was assigned                                     
            pursuant to the provisions of section 7443A(b)(3) and Rules 180,                               
            181, and 182.1                                                                                 
                  Respondent determined a deficiency in petitioners' Federal                               
            income tax for the taxable year 1991 in the amount of $9,957.                                  

            1   Section references are to the Internal Revenue Code in effect for the                      
            year in issue, and Rule references are to the Tax Court Rules of Practice and                  

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