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SMITH v. COMMISSIONER

Docket No. 2172-86.

54 T.C.M. 1329 (1987)

T.C. Memo. 1987-613

William Moore Smith v. Commissioner.

United States Tax Court.

Filed December 16, 1987.

Attorney(s) appearing for the Case

William Moore Smith, pro se. David S. Kosterlitz, for the respondent.

Memorandum Findings of Fact and Opinion

GOLDBERG, Special Trial Judge:

This case1 was heard pursuant to the provisions of section 7456(d)(3) of the Internal Revenue Code of 1954 (redesignated section 7443A(b)(3) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.2

Respondent determined a deficiency of $5,075 in petitioner's 1982 Federal income...

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