T.C. Memo. 1996-232
UNITED STATES TAX COURT
JOON H. CHONG AND YOUNGCHA KIM CHONG, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6642-94. Filed May 22, 1996.
Joon H. Chong and Youngcha Kim Chong, pro sese.
Terri L. Parrot, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent
1All section references are to the Internal Revenue Code in
effect for the year in issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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