Joseph S. King - Page 1

                                       T.C. Memo. 1997-501                                            

                                     UNITED STATES TAX COURT                                          

                                 JOSEPH S. KING, Petitioner v.                                        
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

                  Docket No. 7532-94.                  Filed November 6, 1997.                        

                  Joseph S. King, pro se.                                                             
           Margaret A. Martin, for respondent.                                                        

                                        MEMORANDUM OPINION                                            
                  GOLDBERG, Special Trial Judge:  This case was assigned                              
           pursuant to the provisions of section 7443A(b)(3) and Rules 180,                           
           181, and 182.1  This matter is before the Court on respondent’s                            
           Motion for Summary Judgment pursuant to Rule 121.                                          

                        All section references are to the Internal Revenue Code                       
           in effect for the years in issue.  All Rule references are to the                          
           Tax Court Rules of Practice and Procedure.                                                 

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