Michael D. and Joan Welch - Page 1

                                 T.C. Memo. 1998-310                                  

                               UNITED STATES TAX COURT                                

                      MICHAEL D. AND JOAN WELCH, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18402-96.             Filed August 24, 1998.                

               Michael D. Welch and Joan Welch, pro se.                               

               Andrew Lee, for respondent.                                            

                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.1  Respondent determined a deficiency in petitioners’ 1993              
          Federal income tax in the amount of $878 and an accuracy-related            

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

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