Eli and Karen Yecheskel - Page 1

                                  T.C. Memo. 1997-89                                   

                               UNITED STATES TAX COURT                                 

                       ELI AND KAREN YECHESKEL, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 10938-95.                Filed February 20, 1997.            

               Eli Yecheskel, pro se.                                                  
               Ruth Perez, for respondent.                                             

                                  MEMORANDUM OPINION                                   

               COUVILLION, Special Trial Judge:  This case was heard                   
          pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.                
               Respondent determined a deficiency of $5,359 in petitioners'            
          Federal income tax for 1992.                                                 

               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.             

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