Joseph C. Stepien - Page 1

          T.C. Memo. 1996-6                                                           

                               UNITED STATES TAX COURT                                

          JOSEPH C. STEPIEN, Petitioner v.                                            
          COMMISSIONER OF INTERNAL REVENUE, Respondent                                

          Docket No. 8161-95.              Filed January 11, 1996.                    

          Raymond N. McCabe, for petitioner.                                          
          Lynne Camillo and Matthew I. Root, for respondent.                          

                                 MEMORANDUM OPINION                                   
               ARMEN, Special Trial Judge:  This matter is presently before           
          the Court on respondent's Motion for Partial Summary Judgment.              
               Respondent seeks a partial summary adjudication that there             
          is an underpayment in petitioner's income tax for the taxable               
          year 1984, and that a portion of such underpayment is                       

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