Sarunas Abraitis - Page 1

                                        T.C. Memo. 1998-239                                              

                                      UNITED STATES TAX COURT                                            

                                 SARUNAS ABRAITIS, Petitioner v.                                         
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

                  Docket No. 25922-96.              Filed July 2, 1998.                                  

                  Sarunas Abraitis, pro se.                                                              
                  John A. Freeman, for respondent.                                                       

                                         MEMORANDUM OPINION                                              

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

            1           Unless otherwise indicated, all section references are                           
            to the Internal Revenue Code in effect for the taxable year in                               
            issue.  All Rule references are to the Tax Court Rules of                                    
            Practice and Procedure.                                                                      

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