Robert C. McKee and Valery W. McKee - Page 1

                                 T.C. Memo. 2004-169                                  

                               UNITED STATES TAX COURT                                

                 ROBERT C. MCKEE AND VALERY W. MCKEE, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     

               Docket No. 4036-03.               Filed July 19, 2004.                 

               Donald L. Feurzeig, for petitioners.                                   
               Charlotte Mitchell, for respondent.                                    

                           SUPPLEMENTAL MEMORANDUM OPINION                            

               MARVEL, Judge:  On June 3, 2004, pursuant to Rule 161,1                
          petitioners filed a timely motion for reconsideration of this               

               *This opinion supplements our previously filed opinion in              
          McKee v. Commissioner, T.C. Memo. 2004-115.                                 
               1All section references are to the Internal Revenue Code in            
          effect at all relevant times, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  

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