T.C. Memo. 1996-91 UNITED STATES TAX COURT MARY LEE SHARER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 22562-92, 13219-93. Filed February 29, 1996. Roderick L. MacKenzie, for petitioner. Kathryn K. Vetter, for respondent. MEMORANDUM OPINION PARR, Judge: These cases were assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. The Court agrees with, and adopts, the Opinion of the Special Trial Judge, which is set forth below. 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue. Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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