Warren Richard Follum - Page 1

                                 T.C. Memo. 1996-474                                  

                               UNITED STATES TAX COURT                                

          WARREN RICHARD FOLLUM, Petitioner v.                                        
          COMMISSIONER OF INTERNAL REVENUE, Respondent                                

          Docket No. 7975-96.                  Filed October 22, 1996.                

          Warren Richard Follum, pro se.                                              
               Jordan S. Musen and Paul G. Topolka, for respondent.                   

                                 MEMORANDUM OPINION                                   
               PANUTHOS, Chief Special Trial Judge:  This case was assigned           
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 183.1                                                              
          This matter is before the Court on respondent's motion to                   
          dismiss for lack of jurisdiction, petitioner's motion to dismiss            

          1  All section references are to the Internal Revenue Code in               
          effect for the years in issue, unless otherwise indicated.  All             
          Rule references are to the Tax Court Rules of Practice and                  

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