T.C. Memo. 1997-516
UNITED STATES TAX COURT
BRETT W. BARNES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23024-95. Filed November 17, 1997.
Brett W. Barnes, pro se.
Ladd C. Brown, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
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