Ronald A. and Kellie Weigelt - Page 2

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          181, and 183.1  The Court agrees with and adopts the opinion of             
          the Special Trial Judge which is set forth below.                           

                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               POWELL, Special Trial Judge:  By notice of deficiency dated            
          May 25, 1995, respondent determined a deficiency in petitioners'            
          Federal income tax for the taxable year 1992 in the amount of               
          $1,348.  At the time the petition was filed, petitioners resided            
          in Federal Way, Washington.                                                 
               The issues are (1) whether petitioners are entitled to a               
          deduction for contributions made to Individual Retirement                   
          Accounts (IRA's), and (2) whether petitioners are entitled to an            
          overpayment of income taxes paid on separation benefits received            
          from the U.S. Army (Army).                                                  
               Petitioners timely filed a petition with this Court                    
          disputing the disallowance of the IRA deduction and claiming an             
          overpayment in the amount of $17,103.  The alleged overpayment              
          results from the inclusion of $70,070.60 in income that                     
          petitioners contend is exempt from taxation under section                   
               The facts concerning the $70,070.60 have their genesis in              
          the disintegration of the Soviet Union and the winding down of              

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

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