Raymond Albert Moorefield - Page 1

                                 T.C. Memo. 1996-98                                   

                               UNITED STATES TAX COURT                                

                       RAYMOND ALBERT MOOREFIELD, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17379-94.          Filed March 5, 1996.                     

               Raymond Albert Moorefield, pro se.                                     
               Maria A. Murphy and Michael Salama, for respondent.                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COHEN, Judge:  Respondent determined a deficiency of                   
          $310,670 in petitioner’s Federal income tax for 1988 and                    
          additions to tax of $77,667 under section 6651(a)(1) and $15,749            
          under section 6653(a)(1).  The issues for decision are whether              
          funds received by petitioner in 1988 constituted taxable income             
          and whether petitioner is liable for the additions to tax                   

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