Willie Mae Barlow Davis - Page 1

                                 T.C. Memo. 1998-248                                  

                               UNITED STATES TAX COURT                                

                       WILLIE MAE BARLOW DAVIS, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4077-96.                      Filed July 7, 1998.           

               Robert E.L. Gilpin and Carla R. Cole, for petitioner.                  
               Robert W. West, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               FAY, Judge:  This matter is before the Court on respondent's           
          motion for partial summary judgment and petitioner's motion for             
          partial summary judgment filed pursuant to Rule 121.  The parties           
          have filed various briefs and memoranda in support of and in                
          opposition to these motions.                                                

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