Tony J. Cavender - Page 1

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                                 T.C. Memo. 2004-33                                   


                               UNITED STATES TAX COURT                                


                           TONY J. CAVENDER, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3822-02.            Filed February 10, 2004.                


               Mark H. Westlake, for petitioner.                                      
               James L. May, Jr., for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               SWIFT, Judge:  Respondent determined a deficiency in                   
          petitioner’s 1998 Federal income tax and additions to tax as                
          follows:                                                                    

                         Additions to Tax                                             
          Deficiency   Sec. 6651(a)(1)  Sec. 6651(a)(2)  Sec. 6654(a)                 
          $63,183         $12,531          $7,518          $2,490