Henry F. Wesselman - Page 1

                                 T.C. Memo. 1996-85                                   

                               UNITED STATES TAX COURT                                

                         HENRY F. WESSELMAN, Petitioner, v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10505-95.      Filed February 28, 1996.                     

               Henry F. Wesselman, pro se.                                            
               John W. Duncan, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge John  F. Dean pursuant to section 7443A(b)(4) and Rules               
          180, 181, and 183.1  The Court agrees with and adopts the opinion           
          of the Special Trial Judge, which is set forth below.                       

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

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