T.C. Memo. 1997-35
UNITED STATES TAX COURT
WILLIAM M. HEZEL, Petitioner v. COMMISSIONER
OF INTERNAL REVENUE, Respondent
Docket Nos. 20862-96, 20863-96. Filed January 21, 1997.
William M. Hezel, pro se.
Peter Reilly and Lloyd E. Mueller, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: These cases were assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and Rule references are to the Tax Court Rules of Practice
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