Derk O. and Julia K. Pehrson - Page 1

                                 T.C. Memo. 1997-344                                  

                               UNITED STATES TAX COURT                                

                    DERK O. AND JULIA K. PEHRSON, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 343-96.               Filed July 28, 1997.                       

          Derk O. Pehrson, pro se.                                                    
          Richard W. Kennedy, for respondent.                                         

                                 MEMORANDUM OPINION                                   

          COUVILLION, Special Trial Judge:  This case was heard                       
          pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1               

          1     Unless otherwise indicated, section references are to the             
          Internal Revenue Code in effect for the year at issue.  All Rule            
          references are to the Tax Court Rules of Practice and Procedure.            
          Although respondent determined a deficiency and addition to tax             
          totaling $10,193, the amount of deficiency placed in dispute by             
          petitioners (within the meaning of sec. 7463) does not exceed               

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