T.C. Memo. 1996-499
UNITED STATES TAX COURT
LEE W. YATES AND WENDY S. YATES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3121-95. Filed November 6, 1996.
Bruce J. Berger, for petitioner.
Andrew P. Crousore, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 Respondent determined deficiencies in
1 All section references are to the Internal Revenue Code
as amended, unless otherwise indicated. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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