Paul T. and Carolyn Jackson - Page 1

                                 T.C. Memo. 1999-139                                  

                               UNITED STATES TAX COURT                                

                      PAUL T. & CAROLYN JACKSON, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11724-98.              Filed April 26, 1999.                

               Robert T. Bennett, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               FOLEY, Judge:  By notice dated April 16, 1998, respondent              
          determined a $4,355 deficiency and a $3,266 section 6663 penalty            
          relating to petitioners' 1996 Federal income tax.  All 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 Procedure.                                                  

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