Gerald Reginald Paulson - Page 1

                                 T.C. Memo. 1996-560                                  

                               UNITED STATES TAX COURT                                

                       GERALD REGINALD PAULSON, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 433-96.              Filed December 30, 1996.               

               Gerald Reginald Paulson, pro se.                                       
               Blaine Holiday, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.               
               Respondent determined the following deficiencies in Federal            
          income taxes and additions to tax against petitioner:                       

               Unless otherwise indicated, section references are to the              
          Internal Revenue Code in effect for the years at issue.  All Rule           
          references are to the Tax Court Rules of Practice and Procedure.            

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