Peter Pettong and Chung-Yin Chiang - Page 1

                                 T.C. Memo. 1996-377                                  

                               UNITED STATES TAX COURT                                

                 PETER PETTONG AND CHUNG-YIN CHIANG, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3642-94.              Filed August 15, 1996.                

               Peter Pettong Chiang, pro se.                                          
               Stephanie Jensen, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               GOLDBERG, Special Trial Judge:  This case was assigned                 
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 183.1  This matter is before the Court on respondent's             
          motion to dismiss for lack of jurisdiction.  Respondent moved for           
          dismissal on the grounds that the notice of deficiency for                  

          1   All section references are to the Internal Revenue Code as              
          amended, unless otherwise indicated.  All Rule references are to            
          the Tax Court Rules of Practice and Procedure.                              

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