Joann Thompson, F.K.A. Joanne Bates - Page 1

                                 T.C. Memo. 1998-214                                  

                               UNITED STATES TAX COURT                                

                  JOANN THOMPSON, F.K.A. JOANN BATES, Petitioner v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4702-97.                     Filed June 17, 1998.           

               Charles N. Woodward, for petitioner.                                   
               Elizabeth Downs, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
               Respondent determined a deficiency in petitioner's 1994                
          Federal income tax and an addition to tax under section 6651(a)             

               1   Unless otherwise indicated, 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              

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