Thomas R. and Margaret Kennedy - Page 1

                                         T.C. Memo. 1996-360                                              

                                      UNITED STATES TAX COURT                                             

                        THOMAS R. AND MARGARET KENNEDY, Petitioners v.                                    
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 28309-88.                   Filed August 6, 1996.                            

                  Larry Kars, for petitioners.                                                            
                  Cheryl B. Harris, for respondent.                                                       

                                         MEMORANDUM OPINION                                               

                  WRIGHT, Judge:  This matter is before the Court on                                      
            respondent's motion for entry of decision in accordance with a                                
            stipulation of settlement (the stipulation) filed October 11,                                 
            1994.  We must decide whether the subject decision should reflect                             
            an adjustment that is not reflected in the stipulation.                                       

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