Robert J. Bivolcic - Page 1

                                        T.C. Memo. 2000-62                                             

                                     UNITED STATES TAX COURT                                           

                               ROBERT J. BIVOLCIC, Petitioner v.                                       
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 18721-98.                Filed February 28, 2000.                         

                  Robert J. Bivolcic, pro se.                                                          
                  Caroline Ades-Pierri, for respondent.                                                

                                        MEMORANDUM OPINION                                             
                  PAJAK, Special Trial Judge:  Respondent determined a                                 
            deficiency in petitioner's Federal income tax in the amount of                             
            $7,131, an addition to tax under section 6651(a)(1) of $1,198,                             
            and an addition to tax under section 6654 of $239 for the taxable                          
            year 1996.  Unless otherwise indicated, section references are to                          
            the Internal Revenue Code in effect for the year in issue.                                 
                  At trial, respondent conceded the section 6651(a)(1)                                 
            addition to tax.  The Court must decide:  (1) Whether wages                                

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