Robert C. Olson - Page 1

                                 T.C. Memo. 1996-384                                  

                               UNITED STATES TAX COURT                                

                           ROBERT C. OLSON, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 22213-94.                 Filed August 20, 1996.                 

          Larry D. Harvey, for petitioner.                                            
          David P. Monson, for respondent.                                            

                                 MEMORANDUM OPINION                                   
          ARMEN, Special Trial Judge:  This matter is before the Court                
          on respondent's Motion to Dismiss for Lack of Jurisdiction and to           
          Strike Partnership Items (respondent's Motion to Dismiss).  The             
          issue raised by respondent's Motion to Dismiss involves the scope           
          of this Court's jurisdiction in a so-called affected items                  
          proceeding involving additions to tax for negligence and                    
          substantial understatement of income tax.                                   

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