Yousef Rouzmehr - Page 1

                                 T.C. Memo. 1996-20                                   

                               UNITED STATES TAX COURT                                

                   YOUSEF ROUZMEHR, Petitioner v. COMMISSIONER OF                     
                            INTERNAL REVENUE, Respondent                              

               Docket No. 19802-94.              Filed January 23, 1996.              

               Glenn Abel, for petitioner.                                            
               Michelle Ferreira, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               PARR, Judge:  Respondent determined a deficiency in                    
          petitioner's Federal income tax for 1989 in the amount of                   
          $20,400, and a penalty under section 66621 in the amount of                 
          $4,080.  After mutual concessions, which the parties have                   

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

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