David White - Page 1

                                 T.C. Memo. 1998-410                                  

                               UNITED STATES TAX COURT                                

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

               Docket No. 19412-97.               Filed November 13, 1998.            

               David White, pro se.                                                   
               Melanie R. Urban, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               VASQUEZ, Judge:  This case is before the Court on                      
          respondent's motion for summary judgment under Rule 1211 and to             
          impose a penalty under section 6673.  Respondent determined a               
          deficiency of $26,806, an addition to tax of $6,702 under section           

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

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