T.C. Memo. 1996-348
UNITED STATES TAX COURT
JOHN AND LOUISA A. HODEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7435-94. Filed July 31, 1996.
John Hodel, pro se.
Michael D. Zima and Stephen R. Takeuchi, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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