T.C. Memo. 1997-64
UNITED STATES TAX COURT
ASTRIDA TERAUDS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10433-95. Filed February 4, 1997.
Astrida Terauds, pro se.
Gary W. Bornholdt, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and
Rules 180, 181, and 183. The Court agrees with and adopts the
opinion of the Special Trial Judge, which is set forth below.
1
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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