Paul S. and Sharon E. Talchik - Page 1

                                 T.C. Memo. 2003-342                                  

                               UNITED STATES TAX COURT                                

                    PAUL S. AND SHARON E. TALCHIK, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12419-02.            Filed December 16, 2003.               

               Paul S. and Sharon E. Talchik, pro se.                                 
               Leonard T. Provenzale, for respondent.                                 

                                 MEMORANDUM OPINION                                   

               COUVILLION, Special Trial Judge: Respondent determined a               
          deficiency of $13,974 in petitioners' Federal income tax for                

               1    Unless otherwise indicated, all section references                
          hereafter are to the Internal Revenue Code in effect for the year           
          at issue.  All Rule references are to the Tax Court Rules of                
          Practice and Procedure.  The petition was filed pursuant to sec.            
          7463.  At trial, pursuant to Rule 171(c), petitioners moved,                

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