T.C. Memo. 1996-22
UNITED STATES TAX COURT
ABHIMANYU SWAIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16556-94. Filed January 23, 1996.
Abhimanyu Swain, pro se.
Helen F. Rogers, 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 Respondent determined deficiencies in
1 Unless otherwise indicated, all section references are to the Internal
Revenue Code in effect for the taxable years in issue. All Rule references
are to the Tax Court Rules of Practice and Procedure.
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