Feliciano and Debora Ribera - Page 1

                                 T.C. Memo. 1997-38                                   

                               UNITED STATES TAX COURT                                

                     FELICIANO AND DEBORA RIBERA, Petitioners v.                      
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     

               Docket No. 22678-94.                 Filed January 22, 1997.           

               Feliciano and Debora Ribera, pro se.                                   
               Christian A. Speck, for respondent.                                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  Respondent determined deficiencies in                 
          petitioners' Federal income tax of $13,595 and $2,688 for the               
          1991 and 1992 tax years, respectively.                                      
               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 Procedure.  After concessions,              

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