Perry D. McBroom, Deceased, and Jackie S. McBroom - Page 1

                                       T.C. Memo. 1995-485                                            

                                     UNITED STATES TAX COURT                                          

            PERRY D. McBROOM, DECEASED, AND JACKIE S. McBROOM, Petitioners v.                         
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

                  Docket No. 18847-87.                 Filed October 5, 1995.                         

                  Margaret A. Martin, for respondent.                                                 

                                        MEMORANDUM OPINION                                            
                  GOLDBERG, Judge:  This case was assigned pursuant to the                            
            provisions of section 7443A(b)(3) and Rules 180, 181, and 182,1                           
            and is before the Court on respondent's Motion for Summary                                
            Judgment and Motion to Dismiss as to Petitioner Perry D. McBroom                          
            for Lack of Prosecution.                                                                  
                  Respondent determined a deficiency in petitioners' Federal                          
            income tax for the taxable year 1982 in the amount of $8,288, and                         

            1   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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