Eva J. Madigan - Page 1

                                 T.C. Memo. 1997-383                                  

                               UNITED STATES TAX COURT                                

                            EVA J. MADIGAN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20371-94.                  Filed August 21, 1997.           

               B. Gray Gibbs, for petitioner.                                         
               J. Scot Simpson, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               WRIGHT, Judge:  Respondent determined a deficiency of                  
          $20,238 in petitioner's Federal income tax for taxable year 1991.           
          Respondent further determined that petitioner is liable for                 
          additions to tax under sections 6651(a)1 and 6654 in the amounts            

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect during the year at issue, and           

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