Docket No. 12089-95.

72 T.C.M. 1604 (1996)

T.C. Memo. 1996-562

Mario R. Sanhudo v. Commissioner.

United States Tax Court.

Filed December 30, 1996.

Attorney(s) appearing for the Case

Mario R. Sanhudo, pro se. Blaise G. Dusenberry and Randall B. Pooler, for the respondent.


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 deficiencies in petitioner's Federal income taxes for the taxable years 1991 through 1993 as follows:

Year                                  Deficiency

1991 ..............................     $1...

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