T.C. Memo. 1996-349
UNITED STATES TAX COURT
JAMES L. AND PATRICIA A. CONNELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4924-93. Filed July 31, 1996.
James L. Connell, pro se.
Andrew M. Winkler, for respondent.
MEMORANDUM OPINION
FAY, Judge: This case was assigned to Special Trial Judge
D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules
180, 181, and 183. The Court agrees with and adopts the opinion
of the Special Trial Judge which is set forth below.
1
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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