Reliable Credit Association, Inc. - Page 1

                                 T.C. Memo. 1997-68                                   

                               UNITED STATES TAX COURT                                

                  RELIABLE CREDIT ASSOCIATION, INC., Petitioner v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4283-95.           Filed February 10, 1997.                 

               Neale E. Creamer, for petitioner.                                      
               Shirley M. Francis, for respondent.                                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Carleton D. Powell pursuant to the provisions of section              
          7443A(b)(4) and Rules 180, 181, and 183.1  The Court agrees with            

          1   Unless otherwise indicated, section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  

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