Curtis L. Anderson - Page 1

                                 T.C. Memo. 1999-53                                   

                               UNITED STATES TAX COURT                                

                          CURTIS L. ANDERSON, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10632-97.                Filed February 26, 1999.           

               Thomas E. Towe, for petitioner.                                        
               Joan S. Dennett, 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 deficiencies in petitioner's 1994 and            
          1995 Federal income taxes in the respective amounts of $3,045 and           
          $3,542.  Respondent also determined accuracy-related penalties              

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

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