Dale I. Dirkes - Page 1

                                 T.C. Memo. 2002-60                                   

                               UNITED STATES TAX COURT                                

                            DALE I. DIRKES, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11925-98.              Filed February 28, 2002.             

               Dale I. Dirkes, pro se.                                                
               Frederick W. Krieg, for respondent.                                    

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Daniel J. Dinan pursuant to the provisions of section                 
          7443A(b)(5) and Rules 180, 181, and 183.1  The Court agrees with            

          1  Unless otherwise indicated, section references are to the                
          Internal Revenue Code in effect for the year in issue, and Rule             
          references are to the Tax Court Rules of Practice and Procedure.            

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