Joseph Baldwin Campbell - Page 1

                                        T.C. Memo. 1997-502                                              


                                      UNITED STATES TAX COURT                                            


                             JOSEPH BALDWIN CAMPBELL, Petitioner v.                                      
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

            Docket No. 9244-95.                  Filed November 6, 1997.                                 

            Lawrence H. Crosby, for petitioner.                                                          
            Jonathan P. Decatorsmith, for respondent.                                                    


                                         MEMORANDUM OPINION                                              

            COUVILLION, Special Trial Judge:  This case was heard                                        
            pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.                                

            1     Unless otherwise indicated, section references are to the                              
            Internal Revenue Code in effect for the year at issue.  All Rule                             
            references are to the Tax Court Rules of Practice and Procedure.                             
            At the time the petition was filed, petitioner elected to have                               
            his case considered as a small tax case under sec. 7463.  Prior                              
            to commencement of trial, petitioner moved to have the case                                  
            considered as a regular case under sec. 7443A(b)(3).  The Court                              
                                                                           (continued...)                




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