John Minor - Page 1

                                        T.C. Memo. 1998-237                                             

                                     UNITED STATES TAX COURT                                            

                                    JOHN MINOR, Petitioner v.                                           
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 12653-96.              Filed July 2, 1998.                                 

                  John Minor, pro se.                                                                   
                  John J. Boyle, for respondent.                                                        

                                        MEMORANDUM OPINION                                              

                  DINAN, Special Trial Judge:   This case was heard pursuant                            
            to the provisions of section 7443A(b)(3) and Rules 180, 181, and                            

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

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