Ronald F. and Linda C. Bernard - Page 1

                                 T.C. Memo. 1998-20                                   

                               UNITED STATES TAX COURT                                

                   RONALD F. AND LINDA C. BERNARD, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16480-96.                 Filed January 20, 1998.           

               Ronald F. Bernard, pro se.                                             
               Jeremy McPherson, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  Respondent determined a deficiency in                 
          petitioners' Federal income tax in the amount of $13,029 for the            
          1994 tax year.                                                              
               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.  The sole issue for              

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