David C. Sylvester - Page 1

                                 T.C. Memo. 1999-35                                   

                               UNITED STATES TAX COURT                                

                          DAVID C. SYLVESTER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10777-97.                 Filed February 4, 1999.           

               David C. Sylvester, pro se.                                            
               Jeremy L. McPherson, for respondent.                                   

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
          GOLDBERG, Special Trial Judge:  This case was heard pursuant                
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            
          182.  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 Procedure.                                  

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