John S. Halpern - Page 1

          T.C. Memo. 2000-151                                                            

                                UNITED STATES TAX COURT                                  

                            JOHN S. HALPERN, Petitioner v.                               
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                        

               Docket No. 13245-96.             Filed April 28, 2000.                    

               Richard A. Levine, for petitioner.                                        
               Michael A. Menillo and Tyrone J. Montague, for respondent.                

                                   MEMORANDUM OPINION                                    
               DAWSON, Judge:  This case was assigned to Special Trial                   
          Judge Carleton D. Powell pursuant to Rules 180, 181, and 183.                  
          All Rule references are to the Tax Court Rules of Practice and                 
          Procedure.  The Court agrees with and adopts the opinion of the                
          Special Trial Judge, which is set forth below.                                 
                          OPINION OF THE SPECIAL TRIAL JUDGE                             
               POWELL, Special Trial Judge:  By notice of deficiency                     
          respondent determined additions to tax under sections 6653(a)(1)               

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