Albert J. Miller - Page 1

                                 T.C. Memo. 1997-134                                  

                               UNITED STATES TAX COURT                                

                           ALBERT J. MILLER, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22733-92.            Filed March 17, 1997.                  

               Lawrence V. Brookes, for petitioner.                                   
               Ewan D. Purkiss and Andrew P. Crousore, for respondent.                

                                 MEMORANDUM OPINION                                   
               K�RNER, Judge:  This case is before the Court on                       
          petitioner's motion for summary judgment as supplemented under              
          Rule 121.1  Respondent determined that petitioner, acting as                
          general partner of certain limited partnerships, was personally             

               1  All statutory references are to the Internal Revenue Code           
          in effect for the years in issue, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure, except as                    
          otherwise noted.                                                            

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