T.C. Memo. 1995-573
UNITED STATES TAX COURT
STEVEN H. TOUSHIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21724-92. Filed November 30, 1995.
Angelo Ruggiero and Michael R. Esposito, for petitioner.
Karen P. Wright and Donna C. Hansberry, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case was assigned pursuant
to section 7443A(b)(4) of the Code and Rules 180, 181, and 183.1
1All Rule references are to the Tax Court Rules of Practice
and Procedure. All section references are to the Internal
Revenue Code as amended and in effect during the years in issue.
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