Octavio and Felicitas Olvera - Page 1

                                 T.C. Memo. 1997-488                                  

                               UNITED STATES TAX COURT                                

                    OCTAVIO AND FELICITAS OLVERA, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23237-96.                 Filed October 29, 1997.           

               Octavio Olvera, pro se.                                                
               Joseph T. Ferrick, 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 deficiencies in petitioners' Federal income taxes for            
          1993 and 1994 in the respective amounts of $498 and $1,261.                 

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

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