T.C. Memo. 1996-195
UNITED STATES TAX COURT
ROSA JANUS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 20150-93, 1174-94. Filed April 23, 1996.
Rosa Janus, pro se.
Mayer Y. Silber, Victoria Crosley, and Terri L. Parrott, for
respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WOLFE, Special Trial Judge: These consolidated1 cases were
heard pursuant to the provisions of section 7443A(b)(3) and Rules
1 These cases were consolidated for purposes of trial,
briefing, and opinion by order of this Court dated Aug. 19, 1994.
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