Jerry V. Rice - Page 1


                                 T.C. Memo. 1999-65                                   

                               UNITED STATES TAX COURT                                

                            JERRY V. RICE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4343-97.                     Filed March 5, 1999.           

               Jerry V. Rice, pro se.                                                 
               Pamelya P. Herndon, for respondent.                                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COHEN, Chief Judge:  Respondent determined additions to tax            
          and penalties with respect to petitioner's Federal income tax               
          liabilities as follows:                                                     

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