George W. Brooke and Karen Brooke - Page 1

                                 T.C. Memo. 1996-262                                  


                               UNITED STATES TAX COURT                                


                  GEORGE W. BROOKE AND KAREN BROOKE, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16340-89.           Filed June 7, 1996.                     


               George W. Brooke and Karen Brooke, pro se.                             
               Lavonne D. Lawson, for respondent.                                     


                                 MEMORANDUM OPINION                                   
               WRIGHT, Judge:  This matter is before the Court on                     
          respondent's motion for order to show cause why judgment should             
          not be entered against petitioners on the basis of a previously             
          decided case.  By order dated August 24, 1994, we granted                   
          respondent's motion and ordered petitioners to show cause why               
          judgment should not be entered against them on the basis of the             
          Court's decisions in Wolf v. Commissioner, T.C. Memo. 1991-212,             





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