T.C. Memo. 1996-554
UNITED STATES TAX COURT
BARRY H. AND MARILYN S. SCHEINER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18570-94. Filed December 23, 1996.
Herman B. Rosenthal, for petitioners.
Donna M. Young, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 Respondent determined deficiencies in
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the tax years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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