Michael B. Streiff and Lauren D. Streiff - Page 1

                                 T.C. Memo. 1999-84                                   

                               UNITED STATES TAX COURT                                

              MICHAEL B. STREIFF AND LAUREN D. STREIFF, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12017-97.                   Filed March 23, 1999.           

               Felix S. Jacob, for petitioners.                                       
               Helen F. Rogers, for respondent.                                       
                                 MEMORANDUM OPINION                                   
               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
               Respondent determined a deficiency in petitioners' 1993                
          Federal income tax in the amount of $2,213.  The sole issue is              
          whether certain amounts received by petitioners qualify for                 

          1  Unless otherwise indicated, section references are to the                
          Internal Revenue Code in effect for the year in issue, and Rule             
          references are to the Tax Court Rules of Practice and Procedure.            

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