T.C. Memo. 1996-370
UNITED STATES TAX COURT
MICHAEL AND MICHELLE ROUGH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8354-94. Filed August 12, 1996.
Michael Rough, pro se.
Gregory M. Hahn, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
1 All section references are to the Internal Revenue Code
in effect for the taxable year in issue. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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