T.C. Memo. 1996-160
UNITED STATES TAX COURT
HANS H. AND CHERYL E. HAMMANN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1384-88. Filed March 28, 1996.
Joellyn R. Cattell, 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 For the
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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