G. Richard and Sara B. Childs - Page 1

                                 T.C. Memo. 1996-267                                  

                               UNITED STATES TAX COURT                                

                    G. RICHARD AND SARA B. CHILDS, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7442-94.                     Filed June 11, 1996.           

               G. Richard Childs and Sara B. Childs, pro sese.                        
               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 1990, the taxable year in           
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     

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