Thomas J. Gaffney and Anne F. Gaffney - Page 1

                                 T.C. Memo. 1997-249                                  

                               UNITED STATES TAX COURT                                

                THOMAS J. GAFFNEY AND ANNE F. GAFFNEY, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13092-96.                     Filed June 3, 1997.           

               Thomas J. and Anne F. Gaffney, pro se.                                 
               Gary W. Bornholdt, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               DINAN, Special Trial Judge:   This case was assigned                   
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 182.1                                                              

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

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