William Warren Kelly - Page 1

          T.C. Memo. 2000-32                                                            

                                UNITED STATES TAX COURT                                 

                         WILLIAM WARREN KELLY, Petitioner v.                            
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 2457-98.            Filed January 28, 2000.                   

               William Warren Kelly, pro se.                                            
               Robert V. Boeshaar, for respondent.                                      

                                  MEMORANDUM OPINION                                    
               POWELL, Special Trial Judge:  Respondent determined                      
          deficiencies in petitioner's 1993 and 1994 Federal income taxes               
          in the amounts of $1,631 and $2,014, respectively.  The issue is              
          whether petitioner's aircraft leasing activity is a passive                   
          activity under section 469.1  Petitioner resided in Springfield,              
          Oregon, at the time he filed his petition.                                    

          1    Unless otherwise indicated, all section references are to                
          the Internal Revenue Code in effect for the years in issue.                   

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