Dwight D. Spann - Page 1

                                 T.C. Memo. 1997-235                                  

                               UNITED STATES TAX COURT                                

                           DWIGHT D. SPANN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15339-95.                     Filed May 21, 1997.           

               Dwight D. Spann, pro se.                                               
               Herbert W. Linder, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 182.1                                                              

          1   All section references are to the Internal Revenue Code in              
          effect for the years in issue, and Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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