Carolyn M. Lee - Page 1


                                       T.C. Memo. 1997-201                                            

                                     UNITED STATES TAX COURT                                          

                                 CAROLYN M. LEE, Petitioner v.                                        
            COMMISSIONER OF INTERNAL REVENUE, Respondent                                              

                  Docket No. 3778-94.                       Filed May 1, 1997.                        

                  Jeanne Gramling, for respondent.                                                    

                                        MEMORANDUM OPINION                                            

                  COLVIN, Judge:  This case is before the Court on                                    
            respondent's motion for entry of default judgment under Rule                              
            123(a).1  Respondent alleges that petitioner has abandoned this                           

                  1 Rule references are to the Tax Court Rules of Practice and                        
            Procedure.  Section references are to the Internal Revenue Code                           
            in effect for the years at issue.                                                         

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