Keith R. Basham - Page 1

                                 T.C. Memo. 1999-123                                  

                               UNITED STATES TAX COURT                                

                           KEITH R. BASHAM, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 24676-96.             Filed April 15, 1999.                 

               Keith R. Basham, pro se.                                               
               Donald E. Edwards, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3) of the Internal Revenue            
          Code of 1986, as amended, and Rules 180, 181, and 182 of the Tax            
          Court Rules of Practice and Procedure.  Unless otherwise                    
          indicated, subsequent section references are to the Internal                
          Revenue Code of 1986, as amended and in effect for 1989.                    

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