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
182.1
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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