Shirley Dean Emmons and Charles W. Emmons - Page 1

                                 T.C. Memo. 1998-173                                  

                               UNITED STATES TAX COURT                                

              SHIRLEY DEAN EMMONS AND CHARLES W. EMMONS, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17294-95.                     Filed May 11, 1998.           

               Shirley Dean Emmons and Charles W. Emmons, pro sese.                   
               William I. Miller, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               GALE, Judge:  Respondent determined a deficiency in                    
          petitioners' 1991 Federal income tax in the amount of $13,349, an           
          addition to tax under section 6651(a)(1)1 in the amount of                  

               1 Unless otherwise noted, 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                  

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