T.C. Memo. 2001-309
UNITED STATES TAX COURT
JAMES K. GAUDET, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12832-00. Filed December 7, 2001.
James K. Gaudet, pro se.
Linda A. Neal, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to section 7443A(b)(5) and
Rules 180, 181, and 183. All section references are to the
Internal Revenue Code applicable for the period involved, and all
Rule references are to the Tax Court Rules of Practice and
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