Randal W. Howard - Page 1

                                 T.C. Memo. 1998-57                                   

                               UNITED STATES TAX COURT                                

                           RANDAL W. HOWARD, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20474-90.                Filed February 11, 1998.           

               Randal W. Howard, pro se.                                              
               Rachael J. Zepeda, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.               
               In separate notices of deficiency, respondent determined the           
          following deficiencies in petitioner's Federal income taxes and             
          additions to tax:                                                           

               1    Unless otherwise indicated, 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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