Sharif M. and Amal Battikhi - Page 1

                                 T.C. Memo. 1998-208                                  

                               UNITED STATES TAX COURT                                

                     SHARIF M. AND AMAL BATTIKHI, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 26471-96.              Filed June 16, 1998.                 

               Sharif M. Battikhi and Amal Battikhi, pro se.                          
               Gretchen A. Kindel, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               COLVIN, Judge:  This matter is before the Court on                     
          respondent's motion for summary judgment.  For reasons stated               
          below, we grant respondent's motion.                                        
               Respondent determined a deficiency in petitioners' Federal             
          income tax for 1992 of $8,758 and determined that petitioners are           
          liable for the accuracy-related penalty for negligence under                

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