Richard G. Cook and Patricia A. Cook - Page 1

                                        T.C. Memo. 1997-378                                              

                                      UNITED STATES TAX COURT                                            

                       RICHARD G. AND PATRICIA A. COOK, Petitioners v.                                   
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

                  Docket No. 26918-95.              Filed August 19, 1997.                               

                  Richard G. Cook, pro se.                                                               
                  David W. Sorensen, for respondent.                                                     

                                         MEMORANDUM OPINION                                              

                  COUVILLION, Special Trial Judge:  This case was heard                                  
            pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1                                

                  1     Unless otherwise indicated, section references are to                            
            the Internal Revenue Code in effect for the years at issue.  All                             
            Rule references are to the Tax Court Rules of Practice and                                   
            Procedure.  The petition was filed pursuant to sec. 7463.  At the                            
            commencement of trial, petitioners orally moved that the case be                             
            heard pursuant to sec. 7443A(b)(3).  The Court granted                                       

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