Linda J. Baxter - Page 1

                                 T.C. Memo. 1999-190                                  

                               UNITED STATES TAX COURT                                

                           LINDA J. BAXTER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                 JIMMY R. BAXTER AND JANET S. BAXTER, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 18403-97, 18749-97.         Filed June 10, 1999.           

               James Allen Brown, for petitioner in docket No. 18403-97.              
               James W. Smith, for petitioners in docket No. 18749-97.                
               Donald E. Edwards, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               CARLUZZO, Special Trial Judge:  These consolidated cases               
          were heard pursuant to the provisions of section 7443A(b)(3) of             
          the Internal Revenue Code of 1986, as amended and in effect at              
          the time that the petitions were filed, and Rules 180, 181, and             

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