T.C. Memo. 1997-428
UNITED STATES TAX COURT
JENNIFER A. LESTRANGE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19567-95. Filed September 22, 1997.
Gerald A. Holmes, for petitioner.
Bryan E. Sladek, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) of the Code, and Rules 180, 181, and 182.
All section references are to the Internal Revenue Code in effect
for the taxable year in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner's 1994
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