Paul M. and June S. Sengpiehl - Page 1

                                 T.C. Memo. 1998-23                                   


                               UNITED STATES TAX COURT                                


                    PAUL M. AND JUNE S. SENGPIEHL, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18672-96.                 Filed January 20, 1998.           


               Paul M. Sengpiehl, for petitioners.                                    
               Naseem J. Khan and John Comeau, for respondent.                        

                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to section 7443A(b)(3) and Rules 180, 181, and 182.1                        
               Respondent determined a deficiency in petitioners' Federal             
          income tax for 1991 in the amount of $4,828.                                

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





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