Herbert F. and Lois A. Hewett - Page 1

                                 T.C. Memo. 1996-110                                  

                               UNITED STATES TAX COURT                                

                    HERBERT F. AND LOIS A. HEWETT, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7217-94.           Filed March 7, 1996.                     

               Herbert F. Hewett and Lois A. Hewett, pro se.                          
               C. Glen McLoughlin, for respondent.                                    

                                 MEMORANDUM OPINION                                   
               PAJAK, Special Trial Judge:  This case was heard pursuant to           
          section 7443A(b)(3) of the Code and Rules 180, 181, and 182.                
          Unless otherwise indicated, all section numbers refer to the                
          Internal Revenue Code for the taxable year in issue, and all Rule           
          numbers refer to the Tax Court Rules of Practice and Procedure.             
               Respondent determined a deficiency in petitioners' 1989                
          Federal income tax in the amount of $1,129, as well as an                   

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