Kathie J. Smee, f.k.a. Kathie J. Zavitz - Page 1

                                 T.C. Memo. 1997-364                                  

                               UNITED STATES TAX COURT                                

                      KATHIE J. SMEE, f.k.a. KATHIE J. ZAVITZ,                        
             Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent               

               Docket No. 15958-97.                   Filed August 7, 1997.           

               Julie P. Gasper, 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  This matter           
          is before the Court on the motion to stay proceedings filed by              
          petitioner Kathy J. Smee, f.k.a. Kathie J. Zavitz and                       

          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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