Robert and Mildred Peaco - Page 1

                                 T.C. Memo. 2000-122                                  

                               UNITED STATES TAX COURT                                

                      ROBERT and MILDRED PEACO, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8273-99.                Filed April 6, 2000.                

               Michael B. Yulsman, for petitioners.                                   
               Carol-Lynn E. Moran and Kenneth J. Rubin, for respondent.              

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notice dated February 10, 1999, respondent           
          determined a deficiency of $218,903 relating to petitioners’ 1995           
          Federal income tax.  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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