Mark A. and Juanita D. Murdock - Page 1

                                       T.C. Memo. 1996-518                                             

                                     UNITED STATES TAX COURT                                           

                       MARK A. AND JUANITA D. MURDOCK, Petitioners v.                                  
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 16255-92.                Filed November 25, 1996.                         

                  Mark A. Murdock, pro se.                                                             
                  Timothy S. Murphy, for respondent.                                                   

                                        MEMORANDUM OPINION                                             

                  FAY, Judge:  This case was assigned to Special Trial Judge                           
            D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules                             
            180, 181, and 183.  The Court agrees with and adopts the opinion                           
            of the Special Trial Judge, which is set forth below.                                      

                  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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