T.C. Memo. 2005-26
UNITED STATES TAX COURT
BILLY HYLER AND BONITA M. HYLER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10839-04. Filed February 16, 2005.
Billy and Bonita M. Hyler, pro sese.
James A. Kutten and Melinda Williams, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with
1 All section references are to the Internal Revenue Code,
as amended. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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