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Norton M. Bowman - Page 1

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                                 T.C. Memo. 1997-52                                   


                               UNITED STATES TAX COURT                                


                           NORTON M. BOWMAN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6078-95.                  Filed January 28, 1997.           


               Herman C. Daniel III, for petitioner.                                  
               Deborah C. Stanley, for respondent.                                    


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               WELLS, Judge:  Respondent determined a deficiency of $37,684           
          in petitioner's 1988 Federal income tax.  The issues we must                
          decide are:  (1) Whether a distribution received by petitioner