Jerome V. Mancebo - Page 1

                                 T.C. Memo. 1997-46                                   

                               UNITED STATES TAX COURT                                

                          JEROME V. MANCEBO, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23724-95.                 Filed January 27, 1997.           

               Jerome V. Mancebo, pro se.                                             
               Richard W. Kennedy, 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.               

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

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