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               


               1                                                                      
                   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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