T.C. Memo. 1996-207
UNITED STATES TAX COURT
ROBERT JOSEPH LOOBY and M. PATRICIA LOOBY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10791-94. Filed April 30, 1996.
Robert Joseph Looby and M. Patricia Looby, pro sese.
Thomas S. DiLeonardo, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b) and Rules 180, 181, and 182.1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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