Susan L. Lesinski - Page 1

                                 T.C. Memo. 1997-234                                  


                               UNITED STATES TAX COURT                                


                          SUSAN L. LESINSKI, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 22086-95.                     Filed May 21, 1997.           


               Susan L. Lesinski, pro se.                                             
               Tyron J. Montague and Peter K. Reilly, for respondent.                 


                                 MEMORANDUM OPINION                                   

               TANNENWALD, Judge:  This matter is before the Court on                 
          respondent's motion for leave to file an amendment to answer in             
          which she seeks to recover an asserted erroneous refund.                    
               Petitioner and her husband obtained extensions of time to              
          file their joint Federal income tax return for the taxable year             






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