T.C. Memo. 1996-396
UNITED STATES TAX COURT
ALEX MALESA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12543-93. Filed August 26, 1996.
Alex Malesa, pro se.
J. Anthony Hoefer, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge John F. Dean pursuant to section 7443A(b)(4) and Rules 180,
181, and 183.1 The Court agrees with and adopts the opinion of
the Special Trial Judge which is set forth below.
1Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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