Michael and Michelle Rough - Page 1

                                 T.C. Memo. 1996-370                                  

                               UNITED STATES TAX COURT                                

                     MICHAEL AND MICHELLE ROUGH, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8354-94.                   Filed August 12, 1996.           

               Michael Rough, pro se.                                                 
               Gregory M. Hahn, for respondent.                                       

                                 MEMORANDUM OPINION                                   

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

          1         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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