Abhimanyu Swain - Page 1

                                 T.C. Memo. 1996-22                                   

                               UNITED STATES TAX COURT                                

                           ABHIMANYU SWAIN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16556-94.             Filed January 23, 1996.               

               Abhimanyu Swain, pro se.                                               
               Helen F. Rogers, 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  Respondent determined deficiencies in                       

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

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