James O. Henderson - Page 1

                                 T.C. Memo. 1995-559                                  


                               UNITED STATES TAX COURT                                

                          JAMES O. HENDERSON, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12692-94.           Filed November 27, 1995.                

               John B. Hinton, for petitioner.                                        
               Victor A. Ramirez, for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        


               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 182.1                                                              




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




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