T.C. Memo. 1996-524
UNITED STATES TAX COURT
JOHN AND BETTY RICHARDSON STAFFORD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 994-96. Filed November 27, 1996.
Betty Richardson Stafford, pro se.
Pamela S. Wilson, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
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