Thomas N. Rawlins - Page 1

                                 T.C. Memo. 1995-502                                  


                               UNITED STATES TAX COURT                                

                          THOMAS N. RAWLINS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13383-94.               Filed October 18, 1995.             

               Thomas N. Rawlins, pro se.                                             
               Louis H. Hill, for respondent.                                         

                                 MEMORANDUM OPINION                                   
               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.1  This case was submitted at trial fully stipulated.                   




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




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