T.C. Memo. 1996-531 UNITED STATES TAX COURT RICHARD G. AND ANNE C. GREENE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5293-95. Filed December 2, 1996. Frank Sommerville, for petitioners. Sheri Wilcox, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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