Janet Kline - Page 1

                                         T.C. Memo. 1996-220                                              

                                      UNITED STATES TAX COURT                                             

                                    JANET KLINE, Petitioner v.                                            
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 15500-92.                      Filed May 7, 1996.                            

                  Peter Driscoll, for petitioner.                                                         
                  Diane D. Helfgott, for respondent.                                                      

                                         MEMORANDUM OPINION                                               

                  PANUTHOS, Chief Special Trial Judge:  This case was heard                               
            pursuant to the provisions of section 7443A(b)(3) and Rules 180,                              
            181, and 182.1   Respondent determined additions to petitioner's                              

            1  Unless otherwise indicated, all section references are to                                  
            the Internal Revenue Code in effect for the tax year in issue,                                
            and all Rule references are to the Tax Court Rules of Practice                                

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