T.C. Memo. 1996-65
UNITED STATES TAX COURT
DUDLEY JOSEPH AND MYRNA DUPUY CALLAHAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4863-94. Filed February 20, 1996.
Myrna Dupuy Callahan, pro se.
Linda K. West, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WOLFE, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1 In a notice of deficiency, respondent determined
1 All section references are to the Internal Revenue Code in
effect for the years at issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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