T.C. Memo. 2002-133                                  
                               UNITED STATES TAX COURT                                
                        THOMAS EDWARD VANSTONE, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 16335-99.            Filed May 30, 2002.                    
               Thomas Edward Vanstone, pro se.                                        
               Kevin M. Murphy, 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 as amended and Rule references are to the             
          Tax Court Rules of Practice and Procedure.                                  
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