Ben Cox - Page 1

                                 T.C. Memo. 1996-241                                  

                               UNITED STATES TAX COURT                                

                               BEN COX, Petitioner v.                                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18559-93.                     Filed May 23, 1996.           

               Ben Cox, pro se.                                                       
               Reginald R. Corlew and Stephen R. Takeuchi, for respondent.            

                                 MEMORANDUM OPINION                                   

               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to section 7443A(b)(3) and Rules 180, 181, and 182.1  Respondent            
          determined a deficiency in petitioner's Federal income tax for              
          1990 in the amount of $2,047.  The sole issue for consideration             

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

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