T.C. Memo. 1996-220
UNITED STATES TAX COURT
JANET KLINE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15500-92. Filed May 7, 1996.
Peter Driscoll, for petitioner.
Diane D. Helfgott, for respondent.
MEMORANDUM 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 additions to petitioner's
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the tax year in issue,
and all Rule references are to the Tax Court Rules of Practice
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