Betty W. Thompson - Page 1

                                 T.C. Memo. 1996-468                                  

                               UNITED STATES TAX COURT                                

                          BETTY W. THOMPSON, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18922-93.               Filed October 17,1996.              

               David D. Aughtry and Donald P. Lancaster, for petitioner.              
               Julie M. T. Foster, for respondent.                                    

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge John F. Dean pursuant to section 7443A(b)(4) and Rules 180,           
          181 and 183.1  The Court agrees with and adopts the Special Trial           
          Judge's opinion which is set forth below.                                   

               1Unless otherwise specified, all section references are to             
          the Internal Revenue Code, as amended.  All Rule references are             
          to the Tax Court Rules of Practice and Procedure.                           

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