T.C. Memo. 1997-228
UNITED STATES TAX COURT
MICHAEL G. CORREALE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26760-95. Filed May 13, 1997.
Michael G. Correale, pro se.
Janet J. Johnson, for respondent.
MEMORANDUM OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1994. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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