Robert D. and Anne T. Lewis - Page 1

                                 T.C. Memo. 1996-440                                  

                               UNITED STATES TAX COURT                                

                     ROBERT D. AND ANNE T. LEWIS, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11282-95.               Filed September 25, 1996.           

               Woodford Gregory Rowland, for petitioners.                             
               Patricia Montero, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               DAWSON, Judge:  This case was heard by Special Trial Judge             
          D. Irvin Couvillion pursuant to the provisions of section                   
          7443A(b)(4)1 and Rules 180, 181, and 183.  The Court agrees with            

               Unless otherwise indicated, section references are to the              
          Internal Revenue Code in effect for the years at issue.  All Rule           
          references are to the Tax Court Rules of Practice and Procedure.            

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