T.C. Memo. 1998-2
UNITED STATES TAX COURT
WILLIAM J. WELLS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5458-94. Filed January 5, 1998.
Joyce J. Pearson, for petitioner.
Linas N. Udrys, 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 in petitioner’s 1990 and
1991 Federal income tax in the amounts of $6,513 and $8,043,
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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