T.C. Memo. 1997-433
UNITED STATES TAX COURT
ERIC JENNINGS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4802-97. Filed September 23, 1997.
Eric Jennings, pro se.
Guy A. Bracuti and W. Mark Scott, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and
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