T.C. Memo. 1998-300
UNITED STATES TAX COURT
RANDAL W. HOWARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18627-97. Filed August 19, 1998.
Randal W. Howard, pro se.
Rick V. Hosler and Pamela Wilson-Fuller, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos pursuant to the provisions of
section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
1 All section references are to the Internal Revenue Code,
unless otherwise indicated. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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