T.C. Memo. 1996-497
UNITED STATES TAX COURT
JOHN BRESNAHAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10070-95. Filed November 5, 1996.
Frederick R.H. Witherby, Jr. (specially recognized), for
petitioner.
Mae J. Lew, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case was assigned pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. Dollar amounts are rounded to the nearest dollar.
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