T.C. Memo. 1997-108 UNITED STATES TAX COURT HUGO MADIONI AND SUSANNE J. NICOLAI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20582-95. Filed March 3, 1997. Hugo Madioni Nicolai, pro se. D. Lyndell Pickett, 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,Page: 1 2 3 4 5 Next
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