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                               UNITED STATES TAX COURT                                


                           JACK LANE TAYLOR, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14021-98.                 Filed January 18, 2000.           


               Jack Lane Taylor, pro se.                                              
               Russell D. Pinkerton, for respondent.                                  


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               ARMEN, Special Trial Judge:  Respondent determined a                   
          deficiency in petitioner's Federal income tax for the taxable               
          year 1996 in the amount of $1,298.  The issue for decision is

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