Keith and Janet Scherbart - Page 1

                                 T.C. Memo. 2004-143                                  

                               UNITED STATES TAX COURT                                

                      KEITH AND JANET SCHERBART, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3345-99.             Filed June 17, 2004.                   

               Kathryn J. Sedo and Ryan Kelly, for petitioners.                       
               Blaine C. Holiday, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               PAJAK, Special Trial Judge:  Respondent determined                     
          deficiencies of $3,791 and $2,582 in petitioners’ 1994 and 1995             
          Federal income taxes, 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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