












          T.C. Memo. 2000-11                                                          


                               UNITED STATES TAX COURT                                


                            JOHN W. MARSH, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 27202-96.           Filed January 11, 2000.                 


               Stephen P. Pingree and Richard P. McClellan III, for                   
          petitioner.                                                                 
               Henry E. O'Neill, for respondent.                                      


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        


               RUWE, Judge:  Respondent determined deficiencies in                    
          petitioner's Federal income taxes and additions to tax as                   
          follows:

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