Lloyd Patterson - Page 1

                                 T.C. Memo. 1996-146                                  

                               UNITED STATES TAX COURT                                

                           LLOYD PATTERSON, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1254-94.                   Filed March 25, 1996.            

               Lloyd Patterson, pro se.                                               
               Patricia Riegger, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               PAJAK, Special Trial Judge:  This case was heard pursuant to           
          section 7443A(b)(3) and Rules 180, 181 and 182.  All section                
          numbers refer to the Internal Revenue Code in effect for the                
          taxable year in issue.  All rule numbers refer to the Tax Court             
          Rules of Practice and Procedure.                                            

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