Morton Zuckerman - Page 1

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                                 T.C. Memo. 1997-21                                   


                               UNITED STATES TAX COURT                                


                           MORTON ZUCKERMAN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 10713-93.                 Filed January 13, 1997.           
                                                                                     
               Morton Zuckerman, pro se.                                              
               Laurie B. Kazenoff, Laurence D. Ziegler, and Mark L. Hulse,            
          for respondent.                                                             


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               BEGHE, Judge:  Respondent determined that petitioner and his           
          wife, Pearl Zuckerman (Mrs. Zuckerman), were jointly liable for             
          deficiencies in and additions to their Federal income taxes for             
          1986 and 1987 as follows:1                                                  

               1Unless otherwise indicated, section references are to the             
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