T.C. Memo. 1996-492
UNITED STATES TAX COURT
FRED WILLIE THOMAS, Jr., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13010-94. Filed November 4, 1996.
Donna M. Meek, for petitioner.
Michael D. Zima, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case was assigned pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
Respondent determined deficiencies in and additions to
petitioner's Federal income taxes as follows:
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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