Susan J. Bokhari O'Neil - Page 1

                                 T.C. Memo. 1996-104                                  

                               UNITED STATES TAX COURT                                

                       SUSAN J. BOKHARI O'NEIL, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3952-94.           Filed March 6, 1996.                     

               Susan J. Bokhari O'Neil, pro se.                                       
               Elaine L. Sierra, for respondent.                                      

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge John F. Dean pursuant to the provisions of section                    
          7443A(b)(4) and Rules 180, 181, and 183.1  The Court agrees with            

               1Unless otherwise indicated, all 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                  

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