Brent Allan Pulliam - Page 1

                                 T.C. Memo. 1996-354                                  

                               UNITED STATES TAX COURT                                

                         BRENT ALLAN PULLIAM, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 899-95.                     Filed August 1, 1996.           

               Brent Allan Pulliam, pro se.                                           
               Bryan E. Sladek, 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 a deficiency of $2,479 in petitioner's           
          1992 Federal income tax.  The sole issue for decision is whether            

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

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