T.C. Memo. 1996-141
UNITED STATES TAX COURT
JOSEPH FRANCIS CUNNINGHAM, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22176-93. Filed March 20, 1996.
Kathleen A. Chapman, for petitioner.
Aretha Jones, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was heard 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 for the years in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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