George and Joan Prosman - Page 1

                                 T.C. Memo. 1999-87                                   

                               UNITED STATES TAX COURT                                

                       GEORGE AND JOAN PROSMAN, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 26560-96.                   Filed March 23, 1999.           

               George Prosman, pro se.                                                
               Ronald F. Hood, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
          GOLDBERG, Special Trial Judge:  This case was heard pursuant                
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.  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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