Patricia E. Ietto - Page 1

                                         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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