Charles Robert Schetzer - Page 1

                                 T.C. Memo. 1999-252                                  

                               UNITED STATES TAX COURT                                

                       CHARLES ROBERT SCHETZER, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11089-98.                    Filed July 29, 1999.           
               Charles Robert Schetzer, pro se.                                       
               Deanna R. Kibler, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7443A(b)(3) and Rules 180, 181, and               

          1 Unless otherwise indicated, all section references are to                 
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     

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