Janice L. Morris - Page 1

                                 T.C. Memo. 1996-470                                  


                               UNITED STATES TAX COURT                                


                           JANICE L. MORRIS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4838-95.                  Filed October 21, 1996.           


               Phillip H. Hamilton and John J. Vassen, for petitioner.                
               Darrell C. Weaver, for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               CHIECHI, Judge:  Respondent determined the following defi-             
          ciencies in petitioner's Federal income tax:1                               

          1  In the notice of deficiency (notice), which was issued to both           
          petitioner and her former husband, David E. Morris, Jr. (Mr.                
          Morris or DEM), respondent determined (1) deficiencies in income            
          tax with respect to both of them and (2) additions to tax for               
          fraud only with respect to Mr. Morris.  Mr. Morris filed his own            
          petition with the Court in docket No. 4839-95.  The Court entered           
                                                             (continued...)           




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