T.C. Memo. 1996-264
UNITED STATES TAX COURT
ALLAN R. POWELL AND JOAN K. POWELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3499-93. Filed June 11, 1996.
Edward L. Blanton, Jr., for petitioners.
Alan R. Peregoy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and
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