Diane Cameron Horton - Page 1

                                 T.C. Memo. 1997-572                                  


                               UNITED STATES TAX COURT                                


                         DIANE CAMERON HORTON, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19647-95.              Filed December 29, 1997.             


               Diane Cameron Horton, pro se.                                          
               Patricia Montero and Laurel M. Robinson, for respondent.               

                                 MEMORANDUM OPINION                                   
               PAJAK, Special Trial Judge:  This case was heard pursuant to           
          section 7443A(b)(3) of the Code, and Rules 180, 181, and 182.               
          All section references are to the Internal Revenue Code in effect           
          for the taxable year in issue.  All Rule references are to the              
          Tax Court Rules of Practice and Procedure.                                  
               Respondent determined a deficiency in petitioner's Federal             
          income tax for the year 1992 in the amount of $1,509, and an                




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