William James Courville - Page 1

                                 T.C. Memo. 1996-134                                  

                               UNITED STATES TAX COURT                                

                       WILLIAM JAMES COURVILLE, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 21432-94.                   Filed March 18, 1996.           

               William James Courville, pro se.                                       
               James A. Whitten, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1               
               Respondent determined a deficiency of $2,704 in petitioner's           
          Federal income tax, and an accuracy-related penalty of $541 under           

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

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