James C. and Jane A. Wetzel - Page 1

                                 T.C. Memo. 1997-267                                   

                               UNITED STATES TAX COURT                                 

                     JAMES C. AND JANE A. WETZEL, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 20871-95.                    Filed June 12, 1997.            

               Donald J. O'Connor, for petitioners.                                    
               Marc A. Shapiro, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                         

               POWELL, Special Trial Judge:  This case was assigned                    
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,             
          181, and 182.1                                                               

          1    All section references are to the Internal Revenue Code in              
          effect for the year in issue, and all Rule references are to the             
          Tax Court Rules of Practice and Procedure.                                   

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