Barbara A. Vriner, A.K.A. Barbara A. Coyne - Page 1

                                 T.C. Memo. 1995-465                                  

                               UNITED STATES TAX COURT                                

              BARBARA A. VRINER, A.K.A. BARBARA A. COYNE, Petitioner v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8635-94.              Filed September 28, 1995.             

               Arthur M. Lerner, for petitioner.                                      
               John W. Duncan, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               CLAPP, Judge:  Respondent determined a deficiency in                   
          petitioner's 1987 Federal income tax in the amount of $36,417.              
          After concessions by the parties, the sole issue for decision is            
          whether petitioner is entitled to relief as an innocent spouse              
          for the taxable year 1987.  We hold that she is so entitled.                
               All section references are to the Internal Revenue Code in             
          effect for the year in issue, and all Rule references are to the            

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