T.C. Memo. 1995-592
UNITED STATES TAX COURT
JAMES A. PETRIE IV, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10286-94. Filed December 13, 1995.
James A. Petrie IV, pro se.
Christopher Neal, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1 Respondent determined deficiencies in petitioner's 1990
1 Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the taxable years in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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