Terri L. Steffen - Page 1

                                 T.C. Memo. 2002-229                                  

                               UNITED STATES TAX COURT                                

                           TERRI L. STEFFEN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1296-92.              Filed September 13, 2002.             

               B. Gray Gibbs,* for petitioner.                                        
               Michael A. Pesavento, for respondent.                                  

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               RUWE, Judge:  Respondent determined additions to                       
          petitioner’s1 1986 Federal income tax as follows:                           

               *Mr. Gibbs represented petitioner at trial and on brief.  On           
          Aug. 19, 2002, he was granted leave to withdraw as counsel of               
               1Petitioner and her husband, Paul A. Bilzerian, filed a                

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