Johnnie Everage - Page 1

                                 T.C. Memo. 1997-373                                  

                               UNITED STATES TAX COURT                                

                           JOHNNIE EVERAGE, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2752-97.               Filed August 18, 1997.               

               Johnnie Everage, pro se.                                               
               Steven R. Guest, for respondent.                                       

                                 MEMORANDUM OPINION                                   
               POWELL, Special Trial Judge: This case was heard pursuant              
          to the provisions of section 7443A(b)(3) and Rules 180, 181, and            

               1   Section references are to the Internal Revenue Code in             
          effect for the year at issue, and Rule references are to the Tax            
          Court Rules of Practice and Procedure.                                      

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