T.C. Memo. 1998-355
UNITED STATES TAX COURT
TIMOTHY E. BUTLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13509-97. Filed October 5, 1998.
Timothy E. Butler, pro se.
Michael O'Donnell and George W. Bezold, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1993 and 1994, the
taxable years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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