Pamela O' Rourke - Page 1

                                 T.C. Memo. 1997-152                                  

                               UNITED STATES TAX COURT                                

                           PAMELA O'ROURKE, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6575-95.                    Filed March 24, 1997.           

               Kevin J. Mirch, for petitioner.                                        
               David W. Sorensen, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DEAN, Special Trial Judge:  This case was assigned pursuant            
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
               Respondent determined additions to petitioner's 1982 Federal           
          income tax as follows:                                                      

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

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