Patrick F. and Arlene G. Sheehy - Page 1

                                 T.C. Memo. 1998-183                                  

                               UNITED STATES TAX COURT                                

                  PATRICK F. AND ARLENE G. SHEEHY, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22034-96.              Filed May 18, 1998.                  

               Ralph C. Larsen, for petitioners.                                      
               Christine V. Olsen, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               RAUM, Judge:  The Commissioner determined deficiencies of              
          $31,643 and $1,605 in petitioners' 1992 and 1993 Federal income             
          taxes, respectively.  At issue is whether petitioners are                   
          entitled to deduct an expenditure of $50,000 in connection with             
          their investment in Recyclable Containers Company.  This case was           
          submitted on the basis of a stipulation of facts.                           

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