Paul B. and Jane C. Ding - Page 1

                                 T.C. Memo. 1997-435                                  

                               UNITED STATES TAX COURT                                

                       PAUL B. AND JANE C. DING, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15935-95.               Filed September 24, 1997.           

               Paul B. and Jane C. Ding, pro sese.                                    
               Robert J. Burbank, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.  Unless otherwise indicated, section references are to the             
          Internal Revenue Code in effect for the years at issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            

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