Robert P. Neumann and Sally A. Neumann - Page 1

                                 T.C. Memo. 1998-126                                  

                               UNITED STATES TAX COURT                                

               ROBERT P. NEUMANN AND SALLY A. NEUMANN, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23431-96.                   Filed March 31, 1998.           

               Jon M. Ishibashi, for petitioners.                                     
               Allan E. Staines, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               PAJAK, Special Trial Judge:  This case was heard pursuant to           
          section 7443A(b)(3) of the Code and Rules 180, 181, and 182.  All           
          section references are to the Internal Revenue Code in effect for           
          the years in issue.  All Rule references are to the Tax Court               
          Rules of Practice and Procedure.  Respondent determined additions           
          to tax in petitioners' Federal income taxes as follows:                     

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