Robert Emmett Robertson, III - Page 1

                                T.C. Memo. 2000-217                                   

                               UNITED STATES TAX COURT                                

                     ROBERT EMMETT ROBERTSON, III, Petitioner v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20076-96.           Filed July 18, 2000.                    

                    P and R filed stipulations that resolved most of the              
               issues in this case.  R conceded the issues not resolved by            
               the stipulations.  P asks us to characterize certain items             
               as business income (Sched. C) rather than Sched. B interest            
               income.  The characterization of these items will not change           
               P’s deficiency.                                                        
                    Held:  We decline to hold that the items in question              
               are business income.                                                   

               Robert Emmett Robertson III, pro se.                                   
               Robert E. Williams, Jr., for respondent.                               

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