Edward J. Frami - Page 1

                                 T.C. Memo. 1997-509                                  


                               UNITED STATES TAX COURT                                


                           EDWARD J. FRAMI,  Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8333-96.                 Filed November 12, 1997.           

                                                                                     
               Edward J. Frami, pro se.                                               
               James E. Schacht, for respondent.                                      


          MEMORANDUM FINDINGS OF FACT AND OPINION                                     
               GERBER, Judge:  Respondent determined income tax                       
          deficiencies in the amounts of $11,619 and $12,195 for                      
          petitioner's 1993 and 1994 taxable years, respectively.                     
          Respondent also determined that petitioner's 1993 and 1994 income           
          tax returns were delinquent and that petitioner was liable for              
          additions to tax in the respective amounts of $3,391 and $3,676             





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