Arthur Takamoto and Louise Takamoto - Page 1

                                 T.C. Memo. 1996-94                                   

                               UNITED STATES TAX COURT                                

                 ARTHUR TAKAMOTO AND LOUISE TAKAMOTO, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 36819-84.             Filed March 4, 1996.                  

               David M. Kirsch, for petitioner Louise Takamoto.                       
               Kathey I. Shaw, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 182.1                                                              
               This case is before the Court on petitioner Louise                     
          Takamoto's (petitioner) Motion for Leave to File a Motion to                

          1   All section references are to the Internal Revenue Code                 
          in effect for the year in issue, and Rule references are to the             
          Tax Court Rules of Practice and Procedure.                                  

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