T.C. Memo. 1997-151
UNITED STATES TAX COURT
MARVIN ZIPORYN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12515-95. Filed March 24, 1997.
Marvin Ziporyn, pro se.
Edith E. Siler, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: The case was heard pursuant
to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.1
Respondent determined a deficiency in petitioner's Federal income
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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