Richard J. Montgomery and Adele S. Montgomery - Page 1

                                 T.C. Memo. 1996-263                                  

                               UNITED STATES TAX COURT                                

            RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v.             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8028-94.                     Filed June 11, 1996.           

               Edward L. Blanton, Jr., for petitioners.                               
               Alan R. Peregoy, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Robert N. Armen, Jr., pursuant to the provisions of section           
          7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and           
          Rules 180, 181, and 183.1  The Court agrees with and adopts the             
          Opinion of the Special Trial Judge, which is set forth below.               

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

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