T.C. Memo. 1997-487
UNITED STATES TAX COURT
RICHARD WALTER DRAKE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6119-96. Filed October 28, 1997.
Richard Walter Drake, pro se.
Robert W. Mopsick and William F. Halley, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Petitioner originally elected to have his case heard as a
small tax case. See sec. 7463. Thereafter, pursuant to
petitioner's motion, the "S" designation was removed.
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