Dennis R. Schenk - Page 1

                                    T.C. Memo. 1996-113                                      

                                 UNITED STATES TAX COURT                                     

                             DENNIS R. SCHENK, Petitioner v.                                 
                      COMMISSIONER OF INTERNAL REVENUE, Respondent                           

                Docket No. 21851-94.         Filed March 11, 1996.                           

                Dennis R. Schenk, pro se.                                                    

                Michelle Or, for respondent.                                                 

                                    MEMORANDUM OPINION                                       

                NAMEROFF, Special Trial Judge:  This case was heard pursuant                 
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and                   
          182.1  Respondent determined a deficiency in petitioner's 1988                     
          Federal income tax in the amount of $1,009, plus an addition to                    

          1          All 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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