James Triplett - Page 1

                                 T.C. Memo. 2001-320                                  

                               UNITED STATES TAX COURT                                

                            JAMES TRIPLETT, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19527-97.          Filed December 27, 2001.                 

               James Triplett, pro se.                                                
               Richard J. Hassebrock, for respondent.                                 

                                 MEMORANDUM OPINION                                   

               DAWSON, Judge:  This case was heard by Special Trial Judge             
          Lewis R. Carluzzo pursuant to section 7443A(b)(4) of the Internal           
          Revenue Code of 1986, as amended, in effect at the time the                 
          petition was filed in this case, and Rules 180, 181, and 183 of             
          the Tax Court Rules of Practice and Procedure.  Unless otherwise            
          indicated, subsequent section references are to the Internal                

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