Douglas J. Crawford - Page 3

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          oral testimony and exhibits admitted at trial.  When the petition           
          was filed, petitioner lived in San Diego, California.                       
               Petitioner failed to file an income tax return for the year            
          1991.  Respondent determined a deficiency in petitioner's 1991              
          Federal income tax of $3,074 using information provided by third            
          parties.  In the notice of deficiency, respondent determined that           
          petitioner failed to report wages, interest, and dividends of               
          $23,714 and taxable unemployment compensation of $2,280.                    
          Petitioner claims that $570 of the unemployment compensation he             
          received in 1991 relates to the 1990 taxable year and should not            
          be included in his 1991 gross income.  Petitioner also objects to           
          the assignment of this case to a Special Trial Judge for hearing            
          and decision and asserts that the assignment violates his                   
          constitutional rights.  Petitioner further asserts that the Tax             
          Court is jurisdictionally barred from deciding constitutional               
          1.  Constitutional Arguments                                                
               Petitioner's constitutional arguments are wholly frivolous.            
               Petitioner asserts that the Tax Court is unconstitutional              
          because it was established pursuant to the provisions of Article            
          I of the U.S. Constitution rather than Article III.  This                   
          argument is wholly without merit.  It is well established that              
          functions such as those performed by the Tax Court can be                   

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