Richard Bruce Begelfer - Page 1

                                       T.C. Memo. 1995-455                                              

                                     UNITED STATES TAX COURT                                            

                             RICHARD BRUCE BEGELFER, Petitioner v.                                      
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No.  24056-91.              Filed September 26, 1995.                          

                  Richard Bruce Begelfer, pro se                                                        
                  Bruce M. Wilpon, for respondent.                                                      

                                        MEMORANDUM OPINION                                              
                  GOLDBERG, Special Trial Judge:  This case was heard pursuant                          
            to the provisions of section 7443A(b)(3) and Rules 180, 181, and                            
                  Respondent determined a deficiency in petitioner's Federal                            
            income tax for 1987 in the amount of $6,538 and an addition to                              

            1  All section references are to the Internal Revenue Code as                               
            amended and in effect for the year in issue.  All Rule references                           
            are to the Tax Court Rules of Practice and Procedure.                                       

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