Horace E. McCann - Page 1

                                 T.C. Memo. 1996-120                                  

                               UNITED STATES TAX COURT                                

                           HORACE E. McCANN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 678-95.           Filed March 12, 1996.                     

               Horace E. McCann, pro se.                                              
               Horace Crump, for respondent.                                          

                                 MEMORANDUM OPINION                                   
               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 182.1                                                              
               By notice of deficiency dated November 3, 1994, respondent             
          determined a deficiency in petitioner's 1991 Federal income tax             
          and an accuracy-related penalty pursuant to section 6662(a) in              

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

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