Alan E. and Harriet R. Lewis - Page 1

                                 T.C. Memo. 1995-604                                  

                               UNITED STATES TAX COURT                                

                    ALAN E. AND HARRIET R. LEWIS, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     

               Docket No. 17601-90.      Filed December 26, 1995.                     

               David R. Andelman and Edward F. Fay, for petitioners.                  
               Charles W. Maurer, Jr., for respondent.                                

                           SUPPLEMENTAL MEMORANDUM OPINION                            

               WRIGHT, Judge:  This matter is before the Court on                     
          respondent's Motion for Leave to File Amendment to Answer and               
          petitioner's counter Motion for Summary Judgment.  Both parties             
          filed their respective motions after the Court of Appeals for the           
          First Circuit reversed our opinion, filed at T.C. Memo. 1992-391,           
          and remanded the case to us for further proceedings in accordance           

               *This opinion supplements our opinion in Lewis v.                      
          Commissioner, T.C. Memo. 1992-391.                                          

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