T.C. Memo. 1997-568
UNITED STATES TAX COURT
JAMES BROOKS AND BARBARA BROOKS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
JOHN J. McMAHON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 20859-95, 20860-95. Filed December 23, 1997.
Armondo O. Monaco II, for petitioners.
Bradford A. Johnson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge: These consolidated cases were
heard pursuant to section 7443A(b)(3) and Rules 180, 181, and
182.1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
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