T.C. Memo. 1997-81
UNITED STATES TAX COURT
JOHN DAVID ZIELONKA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20037-95. Filed February 18, 1997.
John David Zielonka, pro se.
Ladd C. Brown, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and
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