T.C. Memo. 1996-267
UNITED STATES TAX COURT
G. RICHARD AND SARA B. CHILDS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7442-94. Filed June 11, 1996.
G. Richard Childs and Sara B. Childs, pro sese.
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 1990, the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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