T.C. Memo. 1996-297
UNITED STATES TAX COURT
JOHN K. JORMAN, JR. AND AUDREY JORMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9379-94. Filed June 26, 1996.
John K. Jorman, pro se.
Brian M. Harrington, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent
determined a deficiency in petitioners' 1991 Federal income tax
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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