T.C. Memo. 1999-98
UNITED STATES TAX COURT
TOM I. LINCIR AND DIANE C. LINCIR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22934-89. Filed March 29, 1999.
Michael D. Savage and Louis Samuel, for petitioners.
Wilton A. Baker and Kim A. Palmerino, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos pursuant to the provisions of
section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
1 All section references are to the Internal Revenue Code of
1954, as amended and in effect for the years in issue, unless
otherwise indicated. All Rule references are to the Tax Court
Rules of Practice and Procedure.
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