T.C. Memo. 1996-147
UNITED STATES TAX COURT
WAYNE E. AND DOROTHY E. WELLS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1580-93. Filed March 25, 1996.
James Dudley Williams, for petitioners.
Donald E. Edwards, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was assigned pursuant
to section 7443A(b)(4) and Rules 180 and 181. All section
references are to the Internal Revenue Code for the taxable years
in issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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