Lawrence W. Wirenius - Page 1

                                 T.C. Memo. 1999-73                                   

                               UNITED STATES TAX COURT                                

                         LAWRENCE W. WIRENIUS, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15414-97.             Filed March 10, 1999.                 

               Lawrence W. Wirenius, pro se.                                          

               Louise Pais, for respondent.                                           

                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and           
               Respondent determined a deficiency in petitioner’s Federal             
          income tax for the taxable year 1994 in the amount of $6,317 plus           
          additions to tax under section 6651(a)(1) in the amount of                  

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

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