T.C. Memo. 1998-86
UNITED STATES TAX COURT
PEPI SCHAFLER, F.K.A PEPI SUMMER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24158-96. Filed February 26, 1998.
Pepi Schafler, pro se.
Roger Bracken, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 Respondent determined a deficiency in
1 All section references are to the Internal Revenue Code
in effect during the year in issue, unless otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
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