Jim L. Westling - Page 1

                                 T.C. Memo. 2000-289                                  

                               UNITED STATES TAX COURT                                

                           JIM L. WESTLING, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 649-98.                 Filed September 15, 2000.           

               Steven R. Stolar and Kristina S. Keller, for petitioner.               
               Ric D. Hulshoff, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioner petitioned the Court to redetermine           
          a $4,255 deficiency in his 1996 Federal income tax.  The                    
          deficiency stems from respondent’s disallowance of an $18,414               
          deduction that petitioner claimed as a miscellaneous itemized               
          deduction for travel expenses connected with his employment as a            
          merchant seaman.  Petitioner ascertained the amount of that                 

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