T.C. Memo. 1998-126
UNITED STATES TAX COURT
ROBERT P. NEUMANN AND SALLY A. NEUMANN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23431-96. Filed March 31, 1998.
Jon M. Ishibashi, for petitioners.
Allan E. Staines, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All
section references are to the Internal Revenue Code in effect for
the years in issue. All Rule references are to the Tax Court
Rules of Practice and Procedure. Respondent determined additions
to tax in petitioners' Federal income taxes as follows:
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