William C. Williams - Page 1
















                                 T.C. Memo. 1999-277                                  


                               UNITED STATES TAX COURT                                


                         WILLIAM C. WILLIAMS, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     


               Docket No. 16359-98.             Filed August 20, 1999.                
                                                                                     
               William C. Williams, pro se.                                           
               Nancy Graml, for respondent.                                           

                                 MEMORANDUM OPINION                                   
               WOLFE, Special Trial Judge: This case was heard pursuant to            
          the provisions of section 7443A(b)(3) and Rules 180, 181, and               
          182.  All section references are to the Internal Revenue Code in            
          effect for the tax year in issue, unless otherwise indicated.               
          All Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               *This opinion replaces T.C. Memo. 1999-270, which was                  
          withdrawn by Order dated August 18, 1999.                                   





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