                        T.C. Memo. 1999-286



                      UNITED STATES TAX COURT



                 CAROL J. JARBOE, Petitioner v.
          COMMISSIONER OF INTERNAL REVENUE, Respondent



     Docket No. 12294-98.             Filed August 27, 1999.



     Carol J. Jarboe, pro se.

     Edward J. Laubach, Jr., for respondent.



                        MEMORANDUM OPINION


     FOLEY, Judge:   By notice dated April 21, 1998, respondent

determined the following deficiencies in, and additions to, Carol

J. Jarboe's Federal income taxes:
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                                        Additions to Tax
Year        Deficiency           Sec. 6651(a)(1)     Sec. 6654
1991          $7,788                 $1,290              $280
1992           7,449                  1,148               188
1995          13,359                  3,340               726
1996          13,625                  3,406               731

All section references are to the Internal Revenue Code in effect

for the years in issue, and all Rule references are to the Tax

Court Rules of Practice and Procedure.

       In a petition filed July 10, 1998, Ms. Jarboe, then a

resident of Marion, Pennsylvania, contested all of respondent's

determinations.    After concessions, the sole issue is whether the

income tax laws are constitutional.

       The parties submitted this case fully stipulated pursuant to

Rule 122.    Ms. Jarboe, a self-employed practical nurse, received

$42,480 and $43,481 of nonemployee compensation from Absolute

Nursing Care, Inc., in 1995 and 1996, respectively.    Ms. Jarboe

also received $1,540 and $1,587 of taxable distributions from

Principal Mutual Life Insurance Co. in 1995 and 1996,

respectively.    In 1995, Ms. Jarboe received $20 of taxable

interest from Blue Ridge Bank.    Ms. Jarboe did not file Federal

income tax returns, and did not pay estimated taxes, relating to

1995 and 1996.

       Ms. Jarboe admits that she received compensation from

Absolute Nursing Care, Inc., distributions from Principal Mutual

Life Insurance Co., and interest from Blue Ridge Bank, but

contends that the tax laws are unconstitutional.    Her contention
                                 -3-

is meritless.   Accordingly, we sustain respondent's

determinations.

     To reflect the foregoing,

                                       Decision will be entered

                                 under Rule 155.
