Domingo Perez - Page 1

                                 T.C. Memo. 1998-442                                  

                               UNITED STATES TAX COURT                                

                            DOMINGO PEREZ, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1994-98.                 Filed December 15, 1998.           

               Domingo Perez, pro se.                                                 
               Anthony Ammirato, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               PANUTHOS, Chief 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 a deficiency in                      

               1  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.                                  

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