James V. & Melinda S. Edmiston - Page 1

                                 T.C. Memo. 1996-60                                   

                               UNITED STATES TAX COURT                                

                   JAMES V. & MELINDA S. EDMISTON, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1760-94.       Filed February 15, 1996.                     

               James V. Edmiston, pro se.                                             
               Margaret S. Rigg, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7443A(b) of the Code and Rules 180,               
          181, and 182.1                                                              

          1All section references are to the Internal Revenue Code in                 
          effect for the taxable year in issue.  All Rule references are to           
          the Tax Court Rules of Practice and Procedure.                              

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