Joseph Francis Cunningham - Page 1

                                 T.C. Memo. 1996-141                                  

                               UNITED STATES TAX COURT                                

                       JOSEPH FRANCIS CUNNINGHAM, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22176-93.               Filed March 20, 1996.               

               Kathleen A. Chapman, for petitioner.                                   
               Aretha Jones, for respondent.                                          

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               CARLUZZO, Special Trial Judge:  This case was heard 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 for the years in issue.  All Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            

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