Dennis C. Gandy - Page 1

                                 T.C. Memo. 1997-532                                  

                               UNITED STATES TAX COURT                                

                           DENNIS C. GANDY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                DENNIS C. GANDY AND CAROLYN S. GANDY, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 26018-93, 26028-93.      Filed December 1, 1997.           

               William A. Roberts and Jeffrey C. Adams, for petitioners.              
               Shelley D. Turner and Audrey M. Morris, for respondent.                

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COHEN, Chief Judge:1  Respondent determined deficiencies in            
          Federal income tax and additions to tax for petitioners Dennis C.           
          and Carolyn S. Gandy as follows:                                            

          1  These consolidated cases were tried before Judge Edna G.                 
          Parker.  Judge Parker died after completion of the trial.  The              
          parties were afforded an opportunity for a new trial, in whole or           
          in part, but they consented to disposition of the cases on the              
          record of the trial before Judge Parker.                                    

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