John H. Hudgens III - Page 1

                                 T.C. Memo. 1997-33                                   

                               UNITED STATES TAX COURT                                

                         JOHN H. HUDGENS III, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7062-94.                  Filed January 21, 1997.           

               John H. Hudgens III, pro se.                                           
               Lawrence B. Austin, for respondent.                                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 182.1                                                              

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

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