Stanley and Gail Laber - Page 1

                                       T.C. Memo. 1997-559                                            

                                     UNITED STATES TAX COURT                                          

                            STANLEY AND GAIL LABER, Petitioners v.                                    
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

                  Docket No. 14800-96.                Filed December 22, 1997.                        

                  Stanley and Gail Laber, pro sese.                                                   
                  Claire R. McKenzie, 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 petitioners’ Federal income tax for                             

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

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