Bonnie A. Broughton - Page 1

                                 T.C. Memo. 1998-409                                  

                               UNITED STATES TAX COURT                                

                         BONNIE A. BROUGHTON, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22996-97.                Filed November 13, 1998.           

               Bonnie A. Broughton, pro se.                                           
               Mary T. Klaasen, for respondent.                                       
                                 MEMORANDUM OPINION                                   
               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1               
               Respondent determined deficiencies in petitioner's Federal             
          income taxes for the taxable years 1994 and 1995 in the                     
          respective amounts of $735 and $752.                                        

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

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