Loretta Manukainiu - Page 1

                                        T.C. Memo. 1998-90                                              

                                     UNITED STATES TAX COURT                                            

                               LORETTA MANUKAINIU, Petitioner v.                                        
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 19920-96.                       Filed March 2, 1998.                       

                  Loretta Manukainiu, pro se.                                                           
                  Margaret S. Rigg, for respondent.                                                     

                                        MEMORANDUM OPINION                                              
                  PAJAK, Special Trial Judge:  This case was heard pursuant to                          
            section 7443A(b)(3) of the Code and Rules 180, 181, and 182.  All                           
            section references are to the Internal Revenue Code in effect for                           
            the year in issue.  All Rule references are to the Tax Court                                
            Rules of Practice and Procedure.                                                            
                  Respondent determined a deficiency in petitioner's 1993                               
            Federal income tax in the amount of $2,833 and an accuracy-                                 

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