Nathan Snyder and Gail Snyder - Page 1

                                 T.C. Memo. 2001-60                                   

                               UNITED STATES TAX COURT                                

                    NATHAN SNYDER AND GAIL SNYDER, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11951-99.                   Filed March 12, 2001.           

               Kenneth E. Keate, for petitioners.                                     
               Melissa J. Hedtke, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               DINAN, Special Trial Judge:  Respondent determined a                   
          deficiency in petitioners’ Federal income tax in the amount of              
          $4,028 for the taxable year 1997.  Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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