T.C. Memo. 1997-155
UNITED STATES TAX COURT
NEMAT MOSTAAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11644-95. Filed March 26, 1997.
Nemat Mostaan, pro se.
Kimberly J. Peterson, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Norman H. Wolfe pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183. All section references
are to the Internal Revenue Code in effect for the tax years in
issue, unless otherwise indicated. All Rule references are to
the Tax Court Rules of Practice and Procedure. The Court agrees
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