Todd A. Clark - Page 1

                                        T.C. Memo. 1997-209                                              

                                      UNITED STATES TAX COURT                                            

                                   TODD A. CLARK, Petitioner v.                                          
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

                  Docket No.  323-96.               Filed May 5, 1997.                                   

                  Robert J. Gumser, for petitioner.                                                      
                  Roberta D. Repasy, for respondent.                                                     

                            MEMORANDUM FINDINGS OF FACT AND OPINION                                      

                  LARO, Judge:  Todd A. Clark petitioned the Court to                                    
            redetermine respondent's determination with respect to his 1991                              
            and 1993 taxable years.  Respondent determined the following                                 
            deficiencies in Federal income taxes and additions thereto:                                  
                                                      Additions to Tax                                  
                                                       Sec.               Sec.                           

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