Richard John Kadunc - Page 1

                                        T.C. Memo. 1997-92                                            

                                     UNITED STATES TAX COURT                                          

                              RICHARD JOHN KADUNC, Petitioner v.                                      
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

            Docket No. 5105-95.                 Filed February 24, 1997.                              

            Richard John Kadunc, pro se.                                                              
            Aretha Jones, for respondent.                                                             

                                        MEMORANDUM OPINION                                            

            COUVILLION, Special Trial Judge:  This case was heard                                     
            pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.                             
            Respondent determined a deficiency of $858 in petitioner's                                
            Federal income tax for 1991.                                                              

            1     Unless otherwise indicated, section references are to the                           
            Internal Revenue Code in effect for the year at issue.  All Rule                          
            references are to the Tax Court Rules of Practice and Procedure.                          

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