Drew Allen Rayner - Page 1

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                                 T.C. Memo. 2002-30                                   


                               UNITED STATES TAX COURT                                


                          DREW ALLEN RAYNER, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5749-00.           Filed January 28, 2002.                  


               Drew Allen Rayner, pro se.                                             
               Linda J. Wise, for respondent.                                         


                                 MEMORANDUM OPINION                                   

               COLVIN, Judge:  Respondent determined that petitioner has an           
          income tax deficiency of $92,384 for 1998 and is liable for an              
          addition to tax under section 6654 of $3,941.12 for failure to              
          pay estimated tax.  The matter is before the Court on                       
          respondent’s motion for summary judgment and motion for a penalty           
          under section 6673.