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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