T.C. Memo. 1996-94
UNITED STATES TAX COURT
ARTHUR TAKAMOTO AND LOUISE TAKAMOTO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 36819-84. Filed March 4, 1996.
David M. Kirsch, for petitioner Louise Takamoto.
Kathey I. Shaw, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1
This case is before the Court on petitioner Louise
Takamoto's (petitioner) Motion for Leave to File a Motion to
1 All section references are to the Internal Revenue Code
in effect for the year in issue, and Rule references are to the
Tax Court Rules of Practice and Procedure.
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