Gene E. & Marilyn Narramore - Page 1

                                        T.C. Memo. 1996-11                                             

                                     UNITED STATES TAX COURT                                           

                         GENE E. & MARILYN NARRAMORE, Petitioners v.                                   
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 34184-87.             Filed January 22, 1996.                             

                  David G. Hendricks, for respondent.                                                  

                                        MEMORANDUM OPINION                                             
                  DAWSON, Judge:  This case was assigned to Special Trial                              
            Judge John J. Pajak pursuant to section 7443A(b)(4) of the Code                            
            and Rules 180, 181, and 183.  Unless otherwise indicated, all                              
            section numbers refer to the Internal Revenue Code for the                                 
            taxable year in issue, and all Rule numbers refer to the Tax                               
            Court Rules of Practice and Procedure.  The Court agrees with and                          

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