T.C. Memo. 1997-244
UNITED STATES TAX COURT
O.H. TOLLEY, JR. AND BETTY TOLLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11407-95. Filed May 29, 1997.
William H. Scheil, Jr., for petitioners.
Veena Luthra, for respondent.
MEMORANDUM OPINION
GOLDBERG, 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' Federal income tax for
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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