T.C. Memo. 1995-599
UNITED STATES TAX COURT
RHETT B. ROSS AND SANDRA L. ROSS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4985-93. Filed December 19, 1995.
Paula M. Junghans, for petitioners.
Alan R. Peregoy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, 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 Unless otherwise indicated, all section references are to the Internal
Revenue Code in effect for 1989, the taxable year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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