T.C. Memo. 1997-307
UNITED STATES TAX COURT
DEAN G. STEELE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14897-96. Filed July 2, 1997.
Dean G. Steele, pro se.
Blake Ferguson and Timothy Lohrstorfer, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 Respondent determined a deficiency in
1 All section references are to the Internal Revenue Code
in effect for the year at issue. All Rule references are to the
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