John Bresnahan - Page 1

                                 T.C. Memo. 1996-497                                  

                               UNITED STATES TAX COURT                                

                            JOHN BRESNAHAN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10070-95.                 Filed November 5, 1996.           

               Frederick R.H. Witherby, Jr. (specially recognized), for               
               Mae J. Lew, for respondent.                                            

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

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year at issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.  Dollar amounts are rounded to the nearest dollar.               

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