Richard Jackson Sleeper - Page 1

                                 T.C. Memo. 1997-367                                  

                               UNITED STATES TAX COURT                                

                       RICHARD JACKSON SLEEPER, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9231-96.               Filed August 11, 1997.               

               Richard Jackson Sleeper, pro se.                                       
               Alvin A. Ohm, for respondent.                                          

                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to section 7443A(b)(3) and Rules 180, 181, and 182.1  Respondent            
          determined deficiencies in petitioner's Federal income taxes in             
          the amounts of $3,232, $4,089, and $4,001 for the taxable years             
          1992, 1993, and 1994, respectively.  The issue for decision is              

          1    Unless otherwise indicated, all section 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              

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