Bill R. and Carolina N. Thomas - Page 1

                                 T.C. Memo. 1996-403                                  

                               UNITED STATES TAX COURT                                

                   BILL R. AND CAROLINA N. THOMAS, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12096-94.                  Filed August 27, 1996.           

               Kenneth Alan Thomas, for petitioners.                                  
               Alvin A. Ohm, for respondent.                                          

                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to section 7443A(b)(3) and Rules 180, 181, and 182.1  Respondent            
          determined a deficiency in petitioners' Federal income tax for              
          1991 in the amount of $1,335.  After concessions, the issue for             

          1    Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year at issue, and              
          all Rule references are to the Tax Court Rules of Practice and              

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