T.C. Memo. 1996-308
UNITED STATES TAX COURT
HARRY T. CAVALARIS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 849-95. Filed July 9, 1996.
Richard Eugene Marsh, Jr., for petitioner.
Jeanne Gramling, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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