Walter E. Peterson - Page 1

                                 T.C. Memo. 1997-463                                  

                               UNITED STATES TAX COURT                                

                          WALTER E. PETERSON, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3398-95.                   Filed October 9, 1997.           

               Walter E. Peterson, pro se.                                            
               Amy Campbell, for respondent.                                          

                                 MEMORANDUM OPINION                                   

               COLVIN, Judge:  Respondent determined that petitioner has a            
          deficiency in Federal income tax for 1992 of $23,768, is liable             
          for self-employment tax of $8,676, and that he is liable for                
          additions to tax of $3,942 for failure to file a return under               
          section 6651(a)(1) and $1,038 for failure to pay estimated tax              
          under section 6654(a).                                                      

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