Dean F. and Jocelyne S. Pace - Page 1

                                 T.C. Memo. 2000-300                                  

                               UNITED STATES TAX COURT                                

                    DEAN F. AND JOCELYNE S. PACE, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14302-99.1              Filed September 25, 2000.           

               Dean F. Pace, pro se.                                                  
               Igor Drabkin, for respondent.                                          

                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  Respondent determined a                
          deficiency in petitioners’ 1995 Federal income tax in the amount            
          of $6,501.  In the notice of deficiency, respondent disallowed a            
          net operating loss (NOL) carryover for 1995 which petitioners               

               1  This case was originally commenced under the Court’s                
          small tax case procedures.  At trial, petitioner moved for and              
          was granted removal of small tax case designation.                          

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