Larry J. and Catherine E. France - Page 22

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          been fully paid by petitioners.  Petitioners’ attempt to add                
          taxable year 1997 to the instant case by way of their amended               
          petition, although understandable in light of the identity of the           
          issues, does not confer jurisdiction on this Court with respect             
          to that year.  We find that we do not have jurisdiction over                
          petitioners’ 1997 taxable year.  The Court, on its own motion,              
          will dismiss and strike taxable year 1997 for lack of                       
          jurisdiction.                                                               
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                        An appropriate order will be                  
                                   issued, and decision will be entered               
                                   under Rule 155.                                    

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