Steven Michael Ryan - Page 1

                                 T.C. Memo. 1997-375                                  

                               UNITED STATES TAX COURT                                

                         STEVEN MICHAEL RYAN, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10828-96.              Filed August 18, 1997.               

               Steven Michael Ryan, pro se.                                           
               Michael J. Calabrese, for respondent.                                  

                                 MEMORANDUM OPINION                                   

               POWELL, Special Trial Judge: This case was heard pursuant to           
          the provisions of section 7443A(b)(3) and Rules 180, 181, and               
               Respondent determined a deficiency in petitioner's 1990                
          Federal income tax and an addition to tax under section                     

               1  Section references are to the Internal Revenue Code in              
          effect for the year at issue, and Rule references are to the Tax            
          Court Rules of Practice and Procedure.                                      

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