Ronald R. Armacost and Cathy L. Armacost - Page 1

                                 T.C. Memo. 1998-150                                   

                               UNITED STATES TAX COURT                                 

              RONALD R. ARMACOST AND CATHY L. ARMACOST, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 19616-96.                   Filed April 27, 1998.            

               Richard P. Algeo, for petitioners.                                      
               Julie L. Payne, for respondent.                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                         
               DEAN, Special Trial Judge:  This case was heard pursuant to             
          section 7443A(b)(3) and Rules 180, 181, and 182.1  Respondent                
          determined a deficiency in Ronald and Cathy Armacost's Federal               
          income taxes for the taxable year 1992 in the amount of $5,470.              

               1Section references are to the Internal Revenue Code in                 
          effect for the year at issue.  Rule references are to the Tax                
          Court Rules of Practice and Procedure.                                       

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