Michael R. and Sheila Olsen - Page 1

                                 T.C. Memo. 1999-331                                  

                               UNITED STATES TAX COURT                                

                     MICHAEL R. AND SHEILA OLSEN, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8282-98.              Filed October 1, 1999.                

               Michael and Sheila Olsen, pro sese.                                    
               Daniel J. Parent, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               WOLFE, Special Trial Judge:  Respondent determined a                   
          deficiency in petitioners' Federal income tax in the amount of              
          $600 for the taxable year 1996.                                             
               This matter is before the Court on respondent's motion for             
          entry of decision.  On April 22, 1999, this case was recalled for           
          trial in San Francisco, California.  After the execution of a               

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