James and Beverly Donehy - Page 1

                                 T.C. Memo. 1996-376                                  

                               UNITED STATES TAX COURT                                

                      JAMES AND BEVERLY DONEHEY, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 8267-96.                   Filed August 14, 1996.                

          James Donehey, pro se.                                                      
          Diane Helfgott and Kristine A. Roth, for respondent.                        

                                 MEMORANDUM OPINION                                   

               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7443A(b)(3) and Rules 180, 181, and               

          1 Unless otherwise indicated, all section references are to                 
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       

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