Donald G. Russell - Page 1

                                 T.C. Memo. 1996-278                                  

                               UNITED STATES TAX COURT                                

                          DONALD G. RUSSELL, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12946-95.                   Filed June 17, 1996.            

               Donald G. Russell, pro se.                                             
               Gary W. Bornholdt, 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 in petitioner's 1992                
          Federal income tax in the amount of $279.                                   
               The sole issue for decision is whether unemployment benefits           
          received by petitioner during the year at issue constitute                  

               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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