T.C. Memo. 1997-364
UNITED STATES TAX COURT
KATHIE J. SMEE, f.k.a. KATHIE J. ZAVITZ,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15958-97. Filed August 7, 1997.
Julie P. Gasper, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter
is before the Court on the motion to stay proceedings filed by
petitioner Kathy J. Smee, f.k.a. Kathie J. Zavitz and
1 Unless otherwise indicated, all 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
Procedure.
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