Lindsey C. Nelson - Page 1

                                        T.C. Memo. 1996-55                                             


                                     UNITED STATES TAX COURT                                           

                                LINDSEY C. NELSON, Petitioner v.                                       
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 733-95.                        Filed February 14, 1996.                   

                  Lindsey C. Nelson, pro se.                                                           
                  Amy Dyar Seals, for respondent.                                                      

                                        MEMORANDUM OPINION                                             

                  POWELL, Special Trial Judge:  Respondent determined                                  
            deficiencies in petitioner's Federal income taxes and accuracy-                            
            related penalties pursuant to section 6662(a)1 in the following                            
            amounts:                                                                                   




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




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