T.C. Memo. 1996-440
UNITED STATES TAX COURT
ROBERT D. AND ANNE T. LEWIS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11282-95. Filed September 25, 1996.
Woodford Gregory Rowland, for petitioners.
Patricia Montero, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was heard by Special Trial Judge
D. Irvin Couvillion pursuant to the provisions of section
7443A(b)(4)1 and Rules 180, 181, and 183. The Court agrees with
1
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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