David Anthony Avery - Page 1

                                 T.C. Memo. 1999-418                                  

                               UNITED STATES TAX COURT                                

                         DAVID ANTHONY AVERY, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9970-98.                 Filed December 23, 1999.           

               David Anthony Avery, pro se.                                           
               Jeanne Gramling, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               POWELL, Special Trial Judge:  Respondent determined a                  
          deficiency in petitioner’s 1994 Federal income tax and an                   
          accuracy-related penalty under section 6662(a)1 in the respective           
          amounts of $4,940 and $988.                                                 

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

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