T.C. Memo. 1997-33
UNITED STATES TAX COURT
JOHN H. HUDGENS III, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7062-94. Filed January 21, 1997.
John H. Hudgens III, pro se.
Lawrence B. Austin, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
POWELL, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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