T.C. Memo. 1996-490
UNITED STATES TAX COURT
PENNEL PHLANDER IRWIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23534-94. Filed October 30, 1996.
Pennel Phlander Irwin, pro se.
Daniel J. Parent, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 Respondent determined deficiencies inpetitioner's
Federal income taxes, and accuracy-related penalties as follows:
1 All section references are to the Internal Revenue Code
as amended, unless otherwise indicated. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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