David Richardson - Page 1

                                 T.C. Memo. 1998-139                                  

                               UNITED STATES TAX COURT                                

                           DAVID RICHARDSON, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12718-97.                   Filed April 14, 1998.           

               David Richardson, pro se.                                              
               Alan R. Peregoy, for respondent.                                       

                                 MEMORANDUM OPINION                                   
               GERBER, Judge:  This case is before the Court on                       
          petitioner's motion to dismiss for lack of jurisdiction, filed              
          March 10, 1998.  Petitioner contends that this case should be               
          dismissed because the notice of deficiency was not sent by                  
          certified or registered mail pursuant to section 6212(a).1                  

               1 All section references are to the Internal Revenue Code in           

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