Travis and Jayne Sanderson - Page 1

                                 T.C. Memo. 1998-358                                  

                               UNITED STATES TAX COURT                                

                     TRAVIS AND JAYNE SANDERSON, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8698-97.               Filed October 5, 1998.               

               Travis and Jayne Sanderson, pro sese.                                  
               Franklin R. Hise, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A and Rules 180, 181, and 182.1            
               Respondent determined a deficiency in petitioners' Federal             

          1  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 Procedure.                                  

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