Alfred P. Duffy - Page 1

                                 T.C. Memo. 1996-556                                  

                               UNITED STATES TAX COURT                                

                           ALFRED P. DUFFY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6723-93.                 Filed December 23, 1996.           

               Alfred P. Duffy, pro se.                                               
               Judith Wilkie, for respondent.                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               ARMEN, Special Trial Judge:  This case was assigned pursuant           
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            

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

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