Gordon B. Cologne - Page 1
















                                 T.C. Memo. 1999-102                                  


                               UNITED STATES TAX COURT                                


                          GORDON B. COLOGNE, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 12298-97.              Filed March 31, 1999.                


               Erla Elizabeth Arnold, for petitioner.                                 
               Christine V. Olsen, for respondent.                                    


                                 MEMORANDUM OPINION                                   

               COHEN, Chief Judge:  Respondent determined a deficiency in             
          petitioner's Federal income tax in the amount of $11,032 for the            
          taxable year 1994.  By amendment to the answer, respondent                  
          asserts an increased deficiency in the amount of $14,297.  The              
          issue for decision is whether petitioner is entitled to deduct as           






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