T.C. Memo. 1996-245
UNITED STATES TAX COURT
REZA AND CONNIE M. REZAZADEH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 15510-94, 6896-95. Filed May 28, 1996.
Reza Rezazadeh, pro se.
James E. Schacht, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: These consolidated cases
were heard pursuant to section 7443A(b)(3)1 and Rules 180, 181,
and 182.
1
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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