Richard M. Kriske - Page 1

                                T.C. Memo. 1999-222                                   

                               UNITED STATES TAX COURT                                

                          RICHARD M. KRISKE, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15368-98.            Filed July 6, 1999.                    

               Richard M. Kriske, pro se.                                             
               Blaine C. Holiday, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to the provisions of section 7443A(b)(3) and Rules 180,            
          181, and 182.1                                                              
               Respondent determined a deficiency in petitioner's 1994                
          Federal income tax in the amount of $2,602.  The issue is whether           

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

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