Daniel E. Godfrey - Page 1

                                 T.C. Memo. 1998-51                                   

                               UNITED STATES TAX COURT                                
                          DANIEL E. GODFREY, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9453-97.                  Filed February 9, 1998.           

               Daniel E. Godfrey, pro se.                                             
               Louise R. Forbes, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               POWELL, Special Trial Judge: This case was heard pursuant to           
          section 7443A(b)(3) and Rules 180, 181, and 182.1                           
               Respondent determined a deficiency in petitioner's 1994                
          Federal income tax in the amount of $751.  Petitioner resided in            
          Winthrop, Massachusetts, at the time the petition was filed.                

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

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