Michael and Christa Dee Richardson - Page 1

                                 T.C. Memo. 1998-236                                  

                               UNITED STATES TAX COURT                                

                 MICHAEL AND CHRISTA DEE RICHARDSON, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5122-97.               Filed July 2, 1998.                  

               Michael Richardson, pro se.                                            
               Richard W. Kennedy, 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 year in issue.  All Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            

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