Gene C. Smith - Page 1

                                 T.C. Memo. 2002-59                                   

                               UNITED STATES TAX COURT                                

                            GENE C. SMITH, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18639-99L.             Filed February 28, 2002.             

               Gene C. Smith, pro se.                                                 
               Joanne B. Minsky, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioner petitioned the Court under section            
          6330(d).1  We decide herein whether his income tax as assessed by           
          respondent for 1985, 1986, 1987, and 1988 should be reduced to              

               1 Section references are to the Internal Revenue Code                  
          applicable to the relevant years.                                           

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