T.C. Memo. 1996-263 UNITED STATES TAX COURT RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8028-94. Filed June 11, 1996. Edward L. Blanton, Jr., for petitioners. Alan R. Peregoy, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge: This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below. 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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