Timothy W. and Suzanne M. Coffield - Page 1

                                 T.C. Memo. 1996-365                                  

                               UNITED STATES TAX COURT                                

                 TIMOTHY W. AND SUZANNE M. COFFIELD, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1205-95.                Filed August 8, 1996.               

               Timothy W. and Suzanne M Coffield, pro se.                             
               Mark S. Mesler, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Carleton D. Powell pursuant to the provisions of section              
          7443A(b)(4) and Rules 180, 181, and 183.1  The Court agrees with            

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

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