MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge:
This case was assigned pursuant to section 7443A(b) (3) of the Internal Revenue Code, as amended and in effect when the petition was filed, and Rules 180, 181, and 182. Unless otherwise indicated, section references are to the Internal Revenue Code, as amended and in effect for the relevant period. Rule references are to the Tax Court Rules of Practice and Procedure.
This case...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.