Rhett B. and Sandra L. Ross - Page 1

                                 T.C. Memo. 1995-599                                  

                               UNITED STATES TAX COURT                                

                  RHETT B. ROSS AND SANDRA L. ROSS, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4985-93.              Filed December 19, 1995.              

               Paula M. Junghans, for petitioners.                                    
               Alan R. Peregoy, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Robert N. Armen, Jr., pursuant to the provisions of section           
          7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and           
          Rules 180, 181, and 183.1  The Court agrees with and adopts the             
          Opinion of the Special Trial Judge, which is set forth below.               

          1 Unless otherwise indicated, all section references are to the Internal    
          Revenue Code in effect for 1989, the taxable year in issue, and all Rule    
          references are to the Tax Court Rules of Practice and Procedure.            

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