Mary C. McDonald - Page 1

                                       T.C. Memo. 1995-503                                            

                                     UNITED STATES TAX COURT                                          

                                MARY C. McDONALD, Petitioner v.                                       
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

                  Docket No. 13217-93.                      Filed October 23, 1995.                   

                  Roderick L. MacKenzie, for petitioner.                                              
                  Kathryn K. Vetter, for respondent.                                                  

                                        MEMORANDUM OPINION                                            

                  RUWE, Judge:  Respondent determined a deficiency of $8,913                          
            in petitioner's 1989 Federal income tax.  Respondent further                              
            determined an accuracy-related penalty pursuant to section                                
            6662(a)1 in the amount of $1,747.                                                         
                  After concessions, the issues for decision are:  (1) Whether                        

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

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