T.C. Memo. 1997-500
UNITED STATES TAX COURT
RICHARD A. McDOWELL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22560-95. Filed November 6, 1997.
Gene M. Carlino, for petitioner.
Carmino J. Santaniello, Jr. and Bradford A. Johnson, for
respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b) of the Code and Rules 180,
181, and 182.1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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