T.C. Memo. 1997-196
UNITED STATES TAX COURT
LINDA GIBBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26551-95. Filed April 29, 1997.
John M. Bjornstad, for petitioner.
Albert B. Kerkhove and Mark E. O'Leary, 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 the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure. Respondent determined deficiencies in petitioner's
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