Robert J. Geiger - Page 1

                                  T.C. Memo. 1999-59                                   

                               UNITED STATES TAX COURT                                 

                           ROBERT J. GEIGER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 3665-97.                     Filed March 1, 1999.            

               Robert J. Geiger, pro se.                                               
               Alan S. Kline, for respondent.                                          

                       MEMORANDUM FINDINGS OF FACT AND 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 in effect at the time the petition              
          was filed, and Rules 180, 181, and 182.  Subsequent section                  
          references are to the Internal Revenue Code in effect for 1992.              
          Rule references are to the Tax Court Rules of Practice and                   

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