Katia V. and Peter Popov - Page 1

                                 T.C. Memo. 1998-374                                  


                               UNITED STATES TAX COURT                                


                      KATIA V. AND PETER POPOV, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 24453-96.                 Filed October 15, 1998.           

               Peter Popov, for petitioners.                                          

               Daniel M. Whitley, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          183.1  Respondent determined a deficiency in petitioners’ 1993              
          Federal income tax in the amount of $2,079 and an accuracy-                 
          related penalty under section 6662(a) in the amount of $416.                

          1  All section references are to the Internal Revenue Code                  
          in effect for the year at issue.  All Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  




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