T.C. Memo. 1996-562
UNITED STATES TAX COURT
MARIO R. SANHUDO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12089-95. Filed December 30, 1996.
Mario R. Sanhudo, pro se.
Blaise G. Dusenberry and Randall B. Pooler, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1
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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