Roger W. and Kathleen Stoy - Page 1

                                 T.C. Memo. 1996-359                                  

                               UNITED STATES TAX COURT                                

                     ROGER W. AND KATHLEEN STOY, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 24961-87.                   Filed August 6, 1996.           

               Larry Kars, for petitioners.                                           
               Cheryl B. Harris, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               WRIGHT, Judge:  This matter is before the Court on                     
          respondent's motion for entry of decision in accordance with a              
          stipulation of settlement (the stipulation) filed October 11,               
          1994.  We must decide whether the subject decision should reflect           
          several adjustments that are not reflected in the stipulation.              

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