T.C. Memo. 1997-152
UNITED STATES TAX COURT
PAMELA O'ROURKE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6575-95. Filed March 24, 1997.
Kevin J. Mirch, for petitioner.
David W. Sorensen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge: This case was assigned pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
Respondent determined additions to petitioner's 1982 Federal
income tax as follows:
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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