Dean W. and Tammy R. May - Page 1

                                 T.C. Memo. 1996-135                                  


                               UNITED STATES TAX COURT                                


                      DEAN W. AND TAMMY R. MAY, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 9607-94.                Filed March 19, 1996.               


               Dean W. May, pro se.                                                   
               Diane L. Worland, for respondent.                                      


                                 MEMORANDUM OPINION                                   
               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.1                                                                       

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




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