T.C. Memo. 1996-240
UNITED STATES TAX COURT
RICHARD L. AND BETTY L. SELTZER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25353-93. Filed May 23, 1996.
Richard L. Seltzer, pro se.
J. Eric Lawson, for respondent.
MEMORANDUM OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent
determined deficiencies in petitioners' 1989, 1990, and 1991
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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