T.C. Memo. 2001-268
UNITED STATES TAX COURT
KIN SANG CHAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16135-99. Filed October 4, 2001.
A. Duane Webber and Dirk Gifford, for petitioner.
William J. Gregg, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge John F. Dean pursuant to the provisions of section
7443A(b)(5), in effect when this case commenced, and Rules 180
and 181 and Interim Rule 183. Unless otherwise indicated,
section references are to the Internal Revenue Code as in effect
for the tax years for which petitioner seeks abatement of
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