Frank C. Verbeck, Jr. - Page 1

                                 T.C. Memo. 1996-339                                  

                               UNITED STATES TAX COURT                                

                        FRANK C. VERBECK, JR., Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1760-96.              Filed July 29, 1996.                  

               Frank C. Verbeck, Jr., pro se.                                         

               Mark A. Weiner, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Larry L. Nameroff pursuant to section 7443A(b)(4) of the              
          Code1 and Rules 180, 181, and 183.  The Court agrees with and               

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

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