Edward Lee Renfrow - Page 1

                                 T.C. Memo. 1995-479                                   

                               UNITED STATES TAX COURT                                 

                          EDWARD LEE RENFROW, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 13734-94.             Filed October 4, 1995.                 

               Edward Lee Renfrow, pro se.                                             
               James Gehres, for respondent.                                           

                                  MEMORANDUM OPINION                                   
               DINAN, Special Trial Judge:   This case was heard pursuant              
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and             

          1         All section references are to the Internal Revenue Code            
          in effect for the taxable year in issue.  All Rule references are            

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