Jose Torres - Page 1

                                 T.C. Memo. 1998-230                                  

                               UNITED STATES TAX COURT                                

                             JOSE TORRES, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15735-97.                    Filed June 29, 1998.           

               Jose Torres, pro se.                                                   
               Susan Kuhn, 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 1994                
          Federal income tax in the amount of $1,280, an addition to tax              

          1    Unless otherwise indicated, 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                  

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