Stephen and Sara Galligan - Page 1

                                 T.C. Memo. 2002-150                                  

                               UNITED STATES TAX COURT                                

                      STEPHEN AND SARA GALLIGAN, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7094-00.                Filed June 13, 2002.                

               Stephen Galligan and Sara Galligan, pro sese.                          
               Blaine C. Holiday, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               PAJAK, Special Trial Judge:  Respondent determined                     
          deficiencies in petitioners’ Federal income tax in the amounts of           
          $2,293 and $1,815 for the taxable years 1996 and 1997,                      
          respectively.  Unless otherwise indicated, section references are           
          to the Internal Revenue Code in effect for the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              

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