Carl W. and Barbara H. Patterson - Page 1

                                 T.C. Memo. 1998-182                                  

                               UNITED STATES TAX COURT                                

                  CARL W. AND BARBARA H. PATTERSON, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10583-96.              Filed May 18, 1998.                  

               Carl W. Patterson and Barbara H. Patterson, pro sese.1                 
               Gregory M. Hahn, for respondent.                                       
                    MEMORANDUM FINDINGS OF FACT AND OPINION                           
               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7443A(b)(3) and Rules 180, 181, and               

          1 At the trial of this case, petitioners were represented by                
          Robert E. Kovacevich, an attorney admitted to practice before               
          this Court.  After trial, however, Mr. Kovacevich was granted               
          leave to withdraw as counsel, and petitioners filed their brief             
          on a pro se basis.                                                          
          2 Unless otherwise indicated, all section references are to                 

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