T.C. Memo. 1998-38
UNITED STATES TAX COURT
WALE O. OSIJO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16925-96. Filed January 28, 1998.
Wale O. Osijo, pro se.
Mark A. Weiner, for respondent.
MEMORANDUM OPINION
NAMEROFF, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and
182. Respondent determined deficiencies and additions to tax in
petitioner’s Federal income tax for the taxable years 1989
through 1994 as set forth below:
1 All section references are to the Internal Revenue Code
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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