James H. Shelton, Deceased, and Eve Shelton - Page 1

                                    T.C. Memo. 1996-444                                      

                                 UNITED STATES TAX COURT                                     

              JAMES H. SHELTON, DECEASED, AND EVE SHELTON, Petitioners v.                    
                      COMMISSIONER OF INTERNAL REVENUE, Respondent                           

                Docket No. 14277-94.               Filed September 26, 1996.                 

                James H. Shelton1 and Eve Shelton, pro sese.                                 
                Charles J. Graves, for respondent.                                           

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

          1James H. Shelton died after this case was submitted.                              
          2Unless otherwise indicated, all section references are to                         
          the Internal Revenue Code in effect for the year in issue.  All                    
          Rule references are to the Tax Court Rules of Practice and                         

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