David E. and Mary R. Price - Page 1

                                 T.C. Memo. 1997-61                                   

                               UNITED STATES TAX COURT                                

                     DAVID E. AND MARY R. PRICE, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7902-95.            Filed February 3, 1997.                 

               David E. Price and Mary R. Price, for petitioners.                     
               Jennifer H. Decker, for respondent.                                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notice of deficiency dated February 15,              
          1995, respondent determined deficiencies in and an addition to              
          petitioners' Federal income taxes as follows:                               
                                                  Addition to Tax                     
                    Year      Deficiency          Sec. 6651(a)(1)                     

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