Nicholas M. Romer - Page 1















                                 T.C. Memo. 2001-168                                  


                               UNITED STATES TAX COURT                                


                          NICHOLAS M. ROMER, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11646-97.                     Filed July 6, 2001.           


               Nicholas M. Romer, pro se.1                                            
               Elizabeth Downs, for respondent.                                       


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               THORNTON, Judge:  Respondent determined the following                  
          deficiencies, additions to tax, and penalties with respect to               





               1 At trial, petitioner was represented by Howard S. Kleyman,           
          who entered his appearance shortly before the trial date and                
          withdrew as attorney of record immediately after the trial.                 




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