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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