Kenneth D. Hanks - Page 1

                                 T.C. Memo. 2001-319                                  

                               UNITED STATES TAX COURT                                

                           KENNETH D. HANKS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13039-00.          Filed December 27, 2001.                 

               Kenneth D. Hanks, pro se.                                              
               Audrey M. Morris, 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) as in effect when this case commenced, and Rules 180,           
          181, and 183. Unless otherwise indicated, subsequent section                
          references are to the Internal Revenue Code as in effect for the            
          tax years for which petitioner seeks abatement of interest.  All            
          Rule references are to the Tax Court Rules of Practice and                  

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