John B. Markham - Page 1

                                 T.C. Memo. 1997-167                                  

                               UNITED STATES TAX COURT                                

          JOHN B. MARKHAM, Petitioner v. COMMISSIONER                                 
          OF INTERNAL REVENUE, Respondent                                             

          Docket No. 23398-96.                   Filed April 7, 1997.                 

          John B. Markham, pro se.                                                    
          Stuart Spielman, for respondent.                                            

                                 MEMORANDUM OPINION                                   

               FAY, Judge:  This case was assigned to Special Trial Judge             
          Robert N. Armen, Jr., pursuant to the provisions of section                 
          7443A(b)(4) and Rules 180, 181, and 183.1  The Court agrees with            

          1  All section references are to the Internal Revenue Code,                 
          as amended, and all Rule references are to the Tax Court Rules of           
          Practice and Procedure.                                                     

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