James Logan Clark - Page 1

                                 T.C. Memo. 1998-280                                  

                               UNITED STATES TAX COURT                                

                          JAMES LOGAN CLARK, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18556-97.                   Filed August 3, 1998.           

               James Logan Clark, pro se.                                             
               Deanna R. Kibler, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               DINAN, Special Trial Judge:   This case was fully stipulated           
          under Rule 122 and was submitted pursuant to the provisions of              
          section 7443A(b)(3) and Rules 180, 181, and 182.1                           

          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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