T.C. Memo. 1998-193
UNITED STATES TAX COURT
SUSAN E. SHORES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3390-97. Filed May 26, 1998.
Audrey J. Orlando, for petitioner.
G. Michelle Ferreira, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief 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 a deficiency in petitioner's
1994 Federal income tax in the amount of $5,354.
1 All section references are to the Internal Revenue Code
in effect for the year in issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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