Raymond and Cynthia Turner-Simmons - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code of 1986, as amended, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
                                  FINDINGS OF FACT                                    
               The parties have filed a stipulation of facts, which, with             
          accompanying exhibits (except for 2-R and 4-J1), is incorporated            
          herein by this reference.  Petitioners resided in Atlanta,                  
          Georgia, at the time the petition was filed.                                
               Petitioners filed a joint Federal income tax return for 1995           
          (the 1995 return), showing a balance due of $2,478.83.                      
          Respondent examined the 1995 return and determined a deficiency             
          in tax of $5,282 (the deficiency).  The examination concluded               
          with petitioners signing an Internal Revenue Service (IRS) Form             
          4549-CG, Income Tax Examination Changes (the Form 4549-CG).  The            
          Form 4549-CG recites only computational changes based on reported           
          self-employment income and a reported pension distribution.  By             
          signing the Form 4549-CG, petitioners agreed to immediate                   
          assessment and collection of the deficiency and interest due to             
          March 1, 1997, and waived their appeal rights with the IRS and              
          their right to contest the deficiency in the Tax Court.                     



               1  Exhibit 2-R was admitted into evidence independent of the           
          stipulation of facts.  Exhibit 4-J was objected to by petitioner            
          and not admitted at trial.  On brief, respondent states that he             
          no longer relies on Exhibit 4-J; therefore, we shall not receive            
          it into evidence.                                                           




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