Denson C. and Linda C. Brumley - Page 1

                                 T.C. Memo. 1998-424                                  

                               UNITED STATES TAX COURT                                

                   DENSON C. AND LINDA C. BRUMLEY, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15751-97.            Filed November 25, 1998.               

               Lorenzo W. Tijerina, for petitioners.                                  
               Franklin R. Hise, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to section 7443A(b)(3) and Rules 180, 181, and 182.1  In a notice           
          of deficiency dated April 23, 1997, respondent determined a                 
          deficiency in petitioners’ Federal income tax for the taxable               

                   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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