Fred Willie Thomas, Jr. - Page 1

                                 T.C. Memo. 1996-492                                  

                               UNITED STATES TAX COURT                                

                       FRED WILLIE THOMAS, Jr., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13010-94.                Filed November 4, 1996.            

               Donna M. Meek, for petitioner.                                         
               Michael D. Zima, for respondent.                                       

                                 MEMORANDUM OPINION                                   
               DEAN, Special Trial Judge:  This case was assigned pursuant            
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
               Respondent determined deficiencies in and additions to                 
          petitioner's Federal income taxes as follows:                               

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

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