Rosemary V. Cocozza - Page 1

                                        T.C. Memo. 1997-305                                              

                                      UNITED STATES TAX COURT                                            

                              ROSEMARY V. COCOZZA, Petitioner v.                                         
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

            Docket No. 639-96.               Filed July 1, 1997.                                         

            Rosemary V. Cocozza, pro se.                                                                 
            J. Scot Simpson, for respondent.                                                             

                                         MEMORANDUM OPINION                                              

            BEGHE, Judge:  This case is before the Court on cross-                                       
            motions for summary judgment under Rule 121.1  For the year 1992,                            
            respondent determined a deficiency of $8,026 in petitioner’s                                 

            1 All Rule references are to the Tax Court Rules of Practice                                 
            and Procedure, and all section references are to the Internal                                
            Revenue Code in effect for the year in issue.                                                

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