Miguel Martin and Claudia P. Palos - Page 1

                                 T.C. Memo. 2000-56                                   

                               UNITED STATES TAX COURT                                

                 MIGUEL MARTIN AND CLAUDIA P. PALOS, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5871-98.                 Filed February 22, 2000.           

               Miguel Martin and Claudia P. Palos, pro sese.                          
               Linette B. Angelastro, for respondent.                                 

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GERBER, Judge:  Respondent determined a $20,244 deficiency             
          in petitioners’ 1994 income tax.  After concessions by                      
          petitioners, the issue remaining for our consideration is whether           
          petitioners are entitled to a casualty loss for earthquake damage           
          caused to a residence owned by them.                                        

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