R. Lawrence Smith, III - Page 1

                                 T.C. Memo. 1998-166                                  

                               UNITED STATES TAX COURT                                
                        R. LAWRENCE SMITH, III, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent.                     

               Docket No. 27511-96.                      Filed May 6, 1998.           

               Herman D. Baker, for petitioner.                                       
               Larry D. Anderson, for respondent.                                     

                                 MEMORANDUM OPINION                                   
               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
               Respondent determined a deficiency in petitioner's 1993                
          Federal income tax and an accuracy-related penalty under section            
          6662(a) in the respective amounts of $6,259 and $1,252.                     

               1  Section references are to the Internal Revenue Code in              
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  

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