Anne S. and Charles G. Vick - Page 1

                                 T.C. Memo. 1996-229                                  

                               UNITED STATES TAX COURT                                

                     ANNE S. AND CHARLES G. VICK, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13694-93.                    Filed May 21, 1996.            

               Anne S. and Charles G. Vick, pro se.                                   
               Martha J. Weber, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.               
               Respondent determined a deficiency of $5,440 in petitioners'           
          1990 Federal income tax.                                                    

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

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