Billye S. Cannon - Page 1

                                 T.C. Memo. 2002-205                                  

                               UNITED STATES TAX COURT                                

                          BILLYE S. CANNON, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13033-00.            Filed August 15, 2002.                 

               Billye S. Cannon, pro se.                                              
               Charles Pillitteri, for respondent.                                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Lewis R. Carluzzo pursuant to section 7443A(b)(5) and Rules           
          180, 181, and 183.1  The Court agrees with and adopts the opinion           

               1  Unless otherwise indicated, section references are to the           
          Internal Revenue Code of 1986, as amended and in effect at the              
          time that the petition was filed.  Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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