public and private organizations, should honor their heroes if they expect to endure. So it is today that the United States Tax Court honors one of its heroes, Judge William M. Drennen. I shall tell you why I thought Bill Drennen was such an outstanding jurist and a great leader of this Court during the 6 years he served as our Chief Judge.

I did not know Bill Drennen personally before I joined the Court, although I was aware of his reputation as a respected tax lawyer, judge, and active member of the ABA Section of Taxation. When I came here, 4 years after he did, we became friends and close colleagues. I frequently sought his advice and assistance. I felt almost immediately that he was destined to succeed Norman Tietjens as our Chief Judge. That happened because he was so admired and trusted by the Judges and the entire Court staff. He was a person with a human touch and a charming smile who inspired loyalty. He epitomized Mark Twain's statement that "the miracle or the power, that elevates the few, is to be found in their industry, application, and perseverance under the promptings of a brave and determined spirit."

In the 9 years before we elected him Chief Judge, Bill Drennen was a prodigious worker. He wrote timely opinions because he believed, as we all should, that justice delayed is justice denied. During that period he heard and decided several significant Federal tax cases. His opinions were well reasoned, scholarly, straightforward, and devoid of ringing rhetoric. He had a clear grasp of the law, a searching and restless intellect, and a remarkable ability to explain complex tax issues in understandable terms. Not only were his opinions models of lucidity, but he seemed to have a real feel for the law and life at the grassroots.

Judge Drennen's opinions covered a wide variety of tax questions. He was regarded as the Court's expert on depletion. A good example is his opinion in Island Creek Coal Co. (43 T.C. 234). Probably no Judge on the Tax Court knew as much as he did about railroads and their tax problems. His opinion in Southern Pacific Transportation Co. (75 T.C. 497), which fills half of volume 75 of the Tax Court Reports, is a classic example of judicial craftsmanship. He also decided important corporate tax cases involving the Gillette Company, National Home Products Company, Columbia Pictures, Inc., Occidental Life Insurance Company, Pepsi-Cola Bottling

Company, and Seattle National Bank. He wrote a number of leading opinions pertaining to Federal estate tax and procedural issues. At times this usually gentle Judge could be toughminded. He had little tolerance for tax protesters who defied the Court's orders and processes. When Stanley Trohimovich, a notorious tax protester, failed to comply with the Court's subpoenas and orders, Judge Drennen found him guilty of criminal contempt and ordered him imprisoned for 30 days as punishment.

In his early years, Judge Drennen was a key member of our Rules, Legislative, and Building Committees. He was often the Court's effective representative and participant at the Taxation Section meetings.

Judge Drennen was a skilled administrator and a successful leader of the highest rank. From the moment he became Chief Judge, he was determined to improve the image and stature of the Court. He knew that by working together we could make the Court better. While he respected the traditions and procedures of the past, he was a pragmatist who believed that nothing remains constant except change itself. He set specific goals and objectives, and he achieved all of them.

Just consider what he accomplished. First, more than any of his predecessors, he built a strong bridge of mutual understanding with the ABA Section of Taxation and established excellent relations with the tax bar throughout the country. In Judge Tannenwald's last address to the Taxation Section, Judge Tannenwald singled out Judge Drennen's significant contribution in that respect.

Second, he worked with the Senate Finance Committee, the House Ways and Means Committee, and Congressional Appropriations Committees to secure the funding (over $30 million) that was needed to build this Courthouse to replace the offices we then occupied in the Internal Revenue Building. He presided at the groundbreaking ceremony. He was actively involved while this building was under construction. He was one of the featured speakers at the courthouse dedication ceremony on November 22, 1974. Another speaker on that occasion was Congressman Tom Steed of Oklahoma, chairman of the House Appropriations subcommittee that had approved our funding. Mr. Steed commented: "You can't say enough about this fellow, Judge Drennen. Year after year

we would get such an impassioned story about the need that this Court had for a building." I will say that had it not been for Bill Drennen's efforts, we would not be in this Courthouse today.

Third, Judge Drennen worked long and hard with the tax writing committees of Congress, with Treasury and IRS officials, and with members of ABA Taxation Section to change the status of the Tax Court to a full-fledged court under Article I of the Constitution. That became part of the Tax Reform Act of 1969. Also, as part of that legislation, the Court's small tax case provisions were enacted. Chief Judge Drennen, who always had a genuine interest and an abiding concern for small taxpayer petitioners, then made the initial appointments of Commissioners, now Special Trial Judges. Two of those appointees were Jim Gussis, a senior Court attorney, and Randy Caldwell, then Clerk of the Court. Shortly thereafter, Judge Drennen appointed our present Clerk of the Court, Charles Casazza. It is interesting to note that many of our key employees today began their service when Judge Drennen was Chief Judge. The Court is certainly a better place because of the good and competent people appointed by him.

Not long after the Tax Reform Act of 1969 became law, our status and jurisdiction as an Article I Court was challenged as being unconstitutional in the case of Burns, Stix, Friedman & Co. (57 T.C. 392). Judge Drennen wrote the Court's majority opinion upholding the constitutionality of our Article I status and jurisdiction. There was also a concurring opinion by Judge Raum that supported the views of the majority. Of course there were no dissents. No Judge looked forward to being run out of here on a rail.

[Laughter.]

JUDGE DAWSON: Fourth, Judge Drennen was intent on revising and modernizing the Tax Court Rules. He therefore directed the Rules Committee to promulgate extensive new Rules that led to the present Tax Court Rules of Practice and Procedure. It was a major project that was finally completed during Judge Drennen's third term as Chief Judge.

Bill Drennen brought greater collegiality to the Court. The Judges and employees had annual picnics and other social and athletic events. Bill was a terrific athlete in many sports-golf, tennis, squash, and baseball-you name it.

Judge Drennen was also a member of the Court's singing trio, known as The Bench Boys, along with Judges Fay and Goffe. [Laughter.] Believe me, they were not in the same league with the famous Beach Boys.

[Laughter.]

JUDGE DAWSON: When I look back at everything Bill Drennen has done for this Court, I must say: What a record! What a record! I think his major contributions to the Court exceeded those of every Chief Judge who served before him and after him, even the revered Judge J. Edgar Murdock. Clearly, Judge Drennen exemplified the three C's of great leadership-courage, commitment, and conviction. In this respect I am reminded of Justice Oliver Wendell Holmes' summation: "Life is action and passion. A man must share the passion of his times at the peril of being judged never to have lived." Bill Drennen was never in peril. He was a man of action who shared the passion of his times and achieved greatly. My guess is that he could have been Chief Judge in perpetuity except for the fact that he wanted his colleagues to share that honor and responsibility.

I was privileged to succeed Judge Drennen as Chief Judge. It was difficult to follow in his footsteps. But, fortunately, he made the transition smoother for me by his unswerving support and encouragement. When I consulted him about some new idea, his response was usually: "Sounds good, Howard; go for it." I always appreciated his advice and assistance. Robert Louis Stevenson wrote: "A friend is a present you give yourself." I know I gave myself a wonderful present years ago when Bill Drennen became my friend.

I thought there was something else that made Bill Drennen very special. He was self-effacing. He never sought nor claimed credit for his achievements. He credited others even when he was in the thick of the action. And, equally important, his pledge was his bond. His words had credibility, his ideas merit, and his actions sincerity.

At past memorial services where we have praised our deceased colleagues as judges and heroes, little recognition has been given to their life partners-their spouses (in most cases, their wives). I am afraid we have been somewhat neglectful in that respect. So that brings me to these comments. What I have said about Bill Drennen would be incomplete without mentioning his friendly and gracious wife,

Maggie, whose love and support was ever present. She too is a remarkable person. For several years she was a teacher. While Bill was judging and they were raising their family, Maggie taught second grade students at the Norwood Parish School. She told me she thought she was a good teacher but not a good disciplinarian. That's probably why the kids liked her so much. She has also been a successful businesswoman. She designed, developed, and managed the Cress Creek Golf and Country Club and its surroundings in Shepherdstown, West Virginia. She is the proud mother of two successful sons and two successful daughters, and many times a grandmother and great-grandmother. During the 60 years Maggie shared with Bill, she gave real meaning to the words "Love bears all things, believes all things, hopes all things, endures all things."

In closing, I suppose we should ask ourselves: How do we say farewell to this good man, this able Judge, who worked so hard, day in and day out, to improve the Tax Court and to make life better for all of us? I think the answer to that question is to repeat what we said to Bill Drennen during his lifetime: "We shall be forever grateful and indebted to you for everything you did. Rest assured that each time we push on into the future and set forth once again toward further greatness and achievements for the Court, you will be one of our guiding stars. Our memory of you, your good deeds, and your legacy of excellence will live on.'

While we are all saddened by Bill Drennen's passing, we are confident that he died as he lived, with grace and dignity, and believing in the joy of life. We hope this truly good man will rest in eternal peace.

JUDGE WELLS: Thank you, Judge Dawson. Now we will hear from Judge Nims. Judge Nims.

JUDGE NIMS: Thank you, Chief Judge Wells. Maggie, I welcome you back to the Tax Court. It seems like you never left.

I would like to say a few words about the importance of Judge Drennen's relationships with the private bar, and particularly the Taxation Section of the American Bar Association. Unlike most of the Judges who were serving at the time Bill was appointed to the Tax Court, he had had no previous experience as a lawyer in the Federal system, except for a brief stint as a U.S. District Court judge's law clerk. His pre-court legal experience thus came almost