Marvin F. and Patricia A. Foster - Page 1

                                 T.C. Memo. 1996-552                                  


                               UNITED STATES TAX COURT                                

                  MARVIN F. AND PATRICIA A. FOSTER, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 15295-95.                Filed December 19, 1996.           


               Marvin F. Foster, pro se.                                              
               Elizabeth Owen, for respondent.                                        


                                 MEMORANDUM OPINION                                   

               DINAN, Special Trial Judge:   This case was heard pursuant             
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.1                                                                       


          1         Unless otherwise indicated, all 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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