Joel Hillman - Page 1

                                  T.C. Memo. 1999-3                                    

                               UNITED STATES TAX COURT                                 

                             JOEL HILLMAN, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 3706-96.                Filed January 5, 1999.               

               Joel Hillman, pro se.                                                   
               Daniel J. Parent, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                         

               FOLEY, Judge:  In a notice dated December 7, 1996,                      
          respondent determined a deficiency, a section 6651(a) addition to            
          tax, and a section 6662(a) penalty relating to Joel Hillman's                
          1991 Federal income tax.  All section references are to the                  
          Internal Revenue Code in effect for the year in issue, and all               
          Rule references are to the Tax Court Rules of Practice and                   

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