Peter Paul Lagasse - Page 1

                                         T.C. Memo. 1996-480                                              

                                      UNITED STATES TAX COURT                                             

                                PETER PAUL LAGASSE, Petitioner v.                                         
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 5319-96.                  Filed October 24, 1996.                            

                  Peter Paul Lagasse, pro se.                                                             
                  Carmino J. Santaniello, for respondent.                                                 

                                         MEMORANDUM OPINION                                               

                  PANUTHOS, Chief Special Trial Judge:  This case was heard                               
            pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.                                 
            Respondent determined a deficiency in petitioner's 1993 Federal                               

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

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