T.C. Memo. 1998-328
UNITED STATES TAX COURT
EMIL FANKHAUSER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11192-95. Filed September 21, 1998.
Kenneth J. Freeman, for petitioner.
Carol A. Szczepanik, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year 1993. Rule
references are to the Tax Court Rules of Practice and Procedure.
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