Mario R. Sanhudo - Page 1

                                    T.C. Memo. 1996-562                                      

                                 UNITED STATES TAX COURT                                     

                             MARIO R. SANHUDO, Petitioner v.                                 
                      COMMISSIONER OF INTERNAL REVENUE, Respondent                           

                Docket No. 12089-95.            Filed December 30, 1996.                     

                Mario R. Sanhudo, pro se.                                                    
                Blaise G. Dusenberry and Randall B. Pooler, for respondent.                  

                         MEMORANDUM FINDINGS OF FACT AND OPINION                             

                PANUTHOS, Chief Special Trial Judge:  This case was heard                    
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,                   
          181, and 182.1                                                                     

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

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