James D. Schlicher - Page 1

                                 T.C. Memo. 1997-163                                  

                               UNITED STATES TAX COURT                                

                          JAMES D. SCHLICHER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 21305-94.                    Filed April 1, 1997.                

               Jon R. Vaught, for petitioner.                                         
               Jeremy McPherson, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               PARR, Judge:  This case is before the Court on petitioner's            
          motion for reasonable litigation costs,1 filed on February 24,              

               1  Petitioner does not request an award of reasonable                  
          administrative costs, because he represented himself throughout             
          the Internal Revenue Service administrative proceedings.                    

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