Olin E. Gibson and Zora M. Gibson - Page 1

                                 T.C. Memo. 1996-140                                  

                               UNITED STATES TAX COURT                                

                  OLIN E. GIBSON AND ZORA M. GIBSON, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17826-94.                  Filed March 20, 1996.            

               Olin E. Gibson, pro se.                                                
               John W. Duncan, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               DEAN, Special Trial Judge:  This case was assigned pursuant            
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
               Respondent determined a deficiency in petitioners' 1991                
          Federal income tax in the amount of $2,502.                                 

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

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