T.C. Memo. 1997-138
UNITED STATES TAX COURT
NICHOLAS O. BACHYNSKY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4597-96. Filed March 17, 1997.
Nicholas O. Bachynsky, pro se.
Melanie R. Urban, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge John J. Pajak pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183. All section references
are to the Internal Revenue Code in effect for the year in issue,
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