Ross William Bruner - Page 1

                                 T.C. Memo. 1998-246                                  

                               UNITED STATES TAX COURT                                

                         ROSS WILLIAM BRUNER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23790-90.                     Filed July 6, 1998.           

               Ross William Bruner, pro se.                                           
               Rick V. Hosler, 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 years in             
          issue.  All Rule references are to the Tax Court Rules of                   

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