T.C. Memo. 1996-475
UNITED STATES TAX COURT
JO ANN PORTER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12537-94. Filed October 22, 1996.
Thomas Smidt II, for petitioner.
Franklin R. Hise, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WOLFE, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. All section references are to the Internal Revenue Code in
effect for the taxable year in issue, unless otherwise indicated.
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