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Ralph Louis Vitale, Jr. - Page 1

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            THIS OPINION APPEARS AS AMENDED BY ORDER DATED JULY 19, 1999.             








                                 T.C. Memo. 1999-131                                  


                               UNITED STATES TAX COURT                                


                       RALPH LOUIS VITALE, Jr., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 346-97.              Filed April 21, 1999.                  


               Ralph Louis Vitale, Jr., pro se.                                       
               William J. Gregg and Judith C. Cohen, for respondent.                  


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FAY, Judge:  Respondent determined deficiencies in peti-               
          tioner's 1993 and 1994 Federal income taxes in the respective               
          amounts of $4,256 and $6,702, and accuracy-related penalties