Ronald L. Berkshire - Page 1

                                        T.C. Memo. 1997-258                                             

                                     UNITED STATES TAX COURT                                            

                               RONALD L. BERKSHIRE, Petitioner v.                                       
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 3006-96.                     Filed June 10, 1997.                          

                  John J. Boyle, for respondent.                                                        

                                        MEMORANDUM OPINION                                              
                  VASQUEZ, Judge:  This case is before the Court on                                     
            respondent's motion for entry of judgment by default pursuant to                            
            Rule 123(a).1  Respondent determined deficiencies in and                                    
            additions to petitioner's Federal income tax as follows:                                    

                  1  All Rule references are to this Court's Rules of Practice                          
            and Procedure, and all section references are to the Internal                               
            Revenue Code as in effect for the years in issue.                                           

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