Arthur B. Crozier - Page 1

                                 T.C. Memo. 1996-312                                  

                               UNITED STATES TAX COURT                                

                   ARTHUR B. CROZIER, Petitioner, v. COMMISSIONER                     
                           OF INTERNAL REVENUE, Respondent                            

               Docket No. 7846-95.                     Filed July 10, 1996.           

               Louis A. Ramunno and Roland Barral, for respondent.                    

                                 MEMORANDUM OPINION                                   
               CHIECHI, Judge:  This case is before the Court on respon-              
          dent's motion for summary judgment pursuant to Rule 121                     
          (motion).1  Respondent determined a deficiency in petitioner's              
          Federal income tax for 1991 in the amount of $13,784 and an                 

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

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