T.C. Memo. 1996-54
UNITED STATES TAX COURT
DAVID E. JACKSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16441-94. Filed February 14, 1996.
David E. Jackson, pro se.
Tyrone Montague, for respondent.
MEMORANDUM OPINION
DINAN, 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 a deficiency in petitioner's 1992
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
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