Docket No. 104-95.

72 T.C.M. 417 (1996)

T.C. Memo. 1996-381

Inez Meilak v. Commissioner.

United States Tax Court.

Filed August 19, 1996.

Attorney(s) appearing for the Case

Kathleen E. Giancana and Carol E. Remy, for the petitioner. Patricia Riegger and Jody Tancer, for the respondent.


PAJAK, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Respondent determined deficiencies in petitioner's Federal income taxes, together with penalties, as follows:


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