Estate of Raymond E. Jones, Deceased, Dorothy J. Jones, Independent Executrix, and Dorothy J. Jones - Page 1

                                 T.C. Memo. 1996-101                                  


                               UNITED STATES TAX COURT                                


              ESTATE OF RAYMOND E. JONES, DECEASED, DOROTHY J. JONES,                 
             INDEPENDENT EXECUTRIX, AND DOROTHY J. JONES, Petitioners v.              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


          Docket No. 23835-88.                 Filed March 6, 1996.                   


               Sidney Levine, for petitioners.                                        
               Melanie R. Urban, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
          WELLS, Judge:  Respondent determined deficiencies in and                    
          additions to petitioners Dorothy J. Jones and Raymond E. Jones'1            

          1                                                                           
               Raymond E. Jones died during 1989, after the notice of                 
          deficiency in the instant case was issued.  The caption of the              
          instant case was amended to substitute the Estate of Raymond E.             
          Jones, Deceased, Dorothy J. Jones, Independent Executrix, for               
          Raymond E. Jones as a petitioner.  For convenience, we will                 
          hereinafter refer to petitioner Dorothy J. Jones as petitioner,             
                                                             (continued...)           




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