T.C. Memo. 1996-82
UNITED STATES TAX COURT
GREGG H. RISNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18494-95. Filed February 26, 1996.
Gregg S. Risner, pro se.
Blaise G. Dusenberry and James E. Archie, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on petitioner's Motion to Shift Burden of Proof to
Respondent.1 As explained in greater detail below, we shall deny
petitioner's motion.
1 All section references are to the Internal Revenue Code
in effect for the tax years at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
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