Kathleen J. Kelly - Page 1

                                       T.C. Memo. 1997-185                                            

                                     UNITED STATES TAX COURT                                          

                               KATHLEEN J. KELLY, Petitioner v.                                       
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

                  Docket No. 10304-94.                   Filed April 21, 1997.                        

                  Kathleen J. Kelly, pro se.                                                          
                  Veena Luthra, for respondent.                                                       
                                        MEMORANDUM OPINION                                            

                  GOLDBERG, Special Trial Judge:  This case was heard pursuant                        
           to section 7443A(b)(3) and Rules 180, 181, and 182.1  Respondent                           
           determined a deficiency in petitioner's Federal income tax for                             
           1989 in the amount of $4,511 and additions to tax pursuant to                              

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

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