Roger Farmer - Page 1

                                 T.C. Memo. 1998-327                                  

                              UNITED STATES TAX COURT                                

                             ROGER FARMER, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18946-96.               Filed September 17, 1998.           

               Roger Farmer, pro se.                                                  

               Michelle Or, for respondent.                                           

                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.1  Respondent determined deficiencies in petitioner's 1990              

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

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