James D. Schlicher - Page 1

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                                 T.C. Memo. 1997-37                                   


                               UNITED STATES TAX COURT                                

                          JAMES D. SCHLICHER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 21305-94.             Filed January 21, 1997.               



               Jon R. Vaught, for petitioner.                                         
               Jeremy McPherson, for respondent.                                      



                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               PARR, Judge:  Respondent determined a deficiency in, and               
          additions to, petitioner's Federal income tax for the taxable               
          year 1988 as follows:                                                       
                                            Additions to Tax                         
          Year     Deficiency     Sec. 6651(a)(1)  Sec. 6654                          
               1988      $98,917        $24,729.25     $6,326.15