Humes Houston Hart - Page 1

                                 T.C. Memo. 1999-186                                   

                               UNITED STATES TAX COURT                                 

                          HUMES HOUSTON HART, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 9355-98.                      Filed June 8, 1999.            

               Humes Houston Hart, pro se.                                             
               Judith Cohen, for respondent.                                           

                                  MEMORANDUM OPINION                                   

               PANUTHOS, Chief Special Trial Judge:  This case was heard               
          pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.                

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

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