T.C. Memo. 1996-121
UNITED STATES TAX COURT
ROBERT P. AND CHRISTINE M. LOLLI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 2752-94, 4272-94. Filed March 12, 1996.
Robert P. Lolli, pro se.
Andrew J. Horning, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: These consolidated cases were
assigned pursuant to the provisions of section 7443A(b)(3) and
Rules 180, 181, and 182.1
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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