Curtis G. and Edna L. Lockett - Page 1

                                 T.C. Memo. 1997-107                                  

                               UNITED STATES TAX COURT                                

                    CURTIS G. AND EDNA L. LOCKETT, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3978-94.                     Filed March 3, 1997.           

               Curtis G. Lockett, pro se.                                             
               Ruth Perez, for respondent.                                            

                                 MEMORANDUM OPINION                                   

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.               
               Respondent determined deficiencies in Federal income taxes             
          of $7,012 and $5,985, respectively, for petitioners' 1991 and               
          1992 tax years.                                                             

               Unless otherwise indicated, section references are to the              
          Internal Revenue Code in effect for the years at issue.  All Rule           
          references are to the Tax Court Rules of Practice and Procedure.            

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