William C. and Katherine H. White - Page 1

                                 T.C. Memo. 1996-438                                  

                               UNITED STATES TAX COURT                                

                  WILLIAM C. AND KATHERINE H. WHITE, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17786-95.               Filed September 25, 1996.           

               William C. and Katherine H. White, pro se.                             
               Roslyn D. Grand, 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 $1,288 in petitioners'           
          1992 Federal income tax.                                                    

               Unless otherwise indicated, 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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