T.C. Memo. 1999-256
UNITED STATES TAX COURT
VINCENT E. & JUDY BOT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7970-98. Filed August 3, 1999.
Garry A. Pearson and Jon J. Jensen, for petitioners.
Blaine C. Holiday, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) 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.
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