T.C. Memo. 1996-428
UNITED STATES TAX COURT
ROGER G. COTNER AND MARLAN W. COTNER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19739-94. Filed September 23, 1996.
Roger G. Cotner, pro se and for petitioner Marlan W. Cotner.
James F. Mauro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
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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