MEMORANDUM OPINION
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's Federal income taxes for 1994, 1995, and 1996 in the amounts of $8,528, $8,671, and $8,479, respectively.
The issue for decision is whether petitioner's Appaloosa horse...
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