T.C. Memo. 1996-463
UNITED STATES TAX COURT
KIRK A. AND IDA R. CRANDALL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8220-94. Filed October 15, 1996.
Kirk A. and Ida R. Crandall, pro sese.
Yolanda R. Garcia and Franklin R. Hise, for respondent.
MEMORANDUM OPINION
WOLFE, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. All section references are to the Internal Revenue Code in
effect for the taxable year in issue, unless otherwise indicated.
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