T.C. Memo. 1999-59
UNITED STATES TAX COURT
ROBERT J. GEIGER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3665-97. Filed March 1, 1999.
Robert J. Geiger, pro se.
Alan S. Kline, 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) of the Internal Revenue
Code of 1986, as amended and in effect at the time the petition
was filed, and Rules 180, 181, and 182. Subsequent section
references are to the Internal Revenue Code in effect for 1992.
Rule references are to the Tax Court Rules of Practice and
Procedure.
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