James E. Stafford - Page 1

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                                 T.C. Memo. 1997-50                                   



                               UNITED STATES TAX COURT                                


                        JAMES E. STAFFORD, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


          Docket No. 4778-95.                  Filed January 28, 1997.                


               James E. Stafford, pro se.                                             
               Susan V. Sample, for respondent.                                       


                                 MEMORANDUM OPINION                                   

          GALE, Judge:  This matter is before the Court on                            
          respondent's motion for summary judgment pursuant to Rule 121.1             
          Respondent determined deficiencies in and additions to                      
          petitioner's Federal income taxes as follows:                               

          1  Unless otherwise indicated, all Rule references are to                   
          the Tax Court Rules of Practice and Procedure, and all chapter              
          and section references are to the Internal Revenue Code in effect           
          for the taxable years at issue.