T.C. Memo. 1997-268
UNITED STATES TAX COURT
TERRY AND KATHRYN A. RODITSKI DILOZIR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3632-96. Filed June 12, 1997.
Terry Dilozir, pro se.
Michael P. Breton, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 Respondent determined a deficiency in
1 All section references are to the Internal Revenue Code
in effect for the year in issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
(continued...)
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