Frederic W. Mercer - Page 1

                                 T.C. Memo. 1997-131                                  

                               UNITED STATES TAX COURT                                

                          FREDERIC W. MERCER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1666-95.                    Filed March 12, 1997.           

               Frederic W. Mercer, pro se.1                                           
               Donald E. Edwards, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               CHIECHI, Judge:  Respondent determined the following                   
          deficiencies in, and additions to, petitioner's Federal income              

          1  Richard Mildren, who has not been admitted to practice before            
          this Court, appeared on behalf of petitioner.  Based on Mr.                 
          Mildren's representation that he possessed the requirements                 
          needed to be admitted to practice before this Court, we specially           
          recognized him to represent petitioner at trial.                            

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