Sid L. Marquis - Page 1

                                 T.C. Memo. 1997-179                                  

                               UNITED STATES TAX COURT                                

                            SID L. MARQUIS, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23372-94.                   Filed April 15, 1997.           

               Sid L. Marquis, pro se.                                                
               David W. Sorensen, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7443A(b) and Rules 180, 181, and 182.1            
               Respondent determined deficiencies in petitioner's 1990 and            
          1991 Federal income taxes in the amounts of $3,919 and $6,376,              

          1All section references are to the Internal Revenue Code in                 
          effect for the taxable years in issue.  All Rule references are             
          to the Tax Court Rules of Practice and Procedure.                           

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