T.C. Memo. 1996-146
UNITED STATES TAX COURT
LLOYD PATTERSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1254-94. Filed March 25, 1996.
Lloyd Patterson, pro se.
Patricia Riegger, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) and Rules 180, 181 and 182. All section
numbers refer to the Internal Revenue Code in effect for the
taxable year in issue. All rule numbers refer to the Tax Court
Rules of Practice and Procedure.
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