T.C. Memo. 1996-332
UNITED STATES TAX COURT
PATRICIA E. IETTO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21265-94. Filed July 24, 1996.
Patricia E. Ietto, pro se.
Brendan G. King, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
POWELL, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1
1 Section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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