Richard L. Pickering - Page 1

                                 T.C. Memo. 1998-142                                  

                               UNITED STATES TAX COURT                                

          RICHARD L. PICKERING, Petitioner v.                                         
          COMMISSIONER OF INTERNAL REVENUE, Respondent                                

          Docket No. 19487-97.                   Filed April 16, 1998.                

          Richard L. Pickering, pro se.                                               
          Richard Fultz, for respondent.                                              

                                 MEMORANDUM OPINION                                   

               ARMEN, Special Trial Judge:  This case was assigned pursuant           
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          This case is before the Court on respondent's Motion to                     
          Dismiss for Lack of Jurisdiction, filed November 25, 1997.  There           

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       

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