T.C. Memo. 1997-7
UNITED STATES TAX COURT
JULIE PUSATERI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7394-95. Filed January 2, 1997.
David B. Crall, for petitioner.
Christine V. Olsen, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All
section references are to the Internal Revenue Code in effect for
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