James M. McGaffin III and Deborah McGaffin - Page 1

                                 T.C. Memo. 1996-290                                  

                               UNITED STATES TAX COURT                                

             JAMES M. McGAFFIN III and DEBORAH McGAFFIN, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2490-94.                     Filed June 24, 1996.           

               James M. and Deborah McGaffin, pro sese.                               
               Lisa K. Hartnett, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7443A(b) and Rules 180, 181, and 182.1            
               Respondent determined a deficiency in petitioners' 1991                
          Federal income tax in the amount of $4,531.  The sole issue for             

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

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