T.C. Memo. 1995-486
UNITED STATES TAX COURT
MARK R. AND DIANE R. WEBB, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16380-93. Filed October 10, 1995.
Michelle Turpin, for petitioners.
James B. Ausenbaugh, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.
Respondent determined a deficiency in Federal income tax of
$2,044 and an addition to tax under section 6651(a)(1) in the
1
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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