Bernard F. Kochevar, Sr. and Marlene C. Kochevar - Page 1

                                 T.C. Memo. 1995-607                                  

                               UNITED STATES TAX COURT                                

                  BERNARD F. KOCHEVAR, SR. AND MARLENE C. KOCHEVAR,                   
             Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent              

               Docket No. 27054-93.                Filed December 26, 1995.           

               Bernard F. Kochevar, Sr. and Marlene C. Kochevar, pro sese.            
               Paul Dixon, for respondent.                                            

                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to section 7443A(b)(3) and Rules 180, 181, and 182.1  Respondent            
          determined a deficiency in petitioners' Federal income tax for              
          the taxable year 1990 in the amount of $6,625, and an addition to           
          tax under section 6651(a)(1) in the amount of $494.                         

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

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