T.C. Memo. 1997-83
UNITED STATES TAX COURT
ALTON W. BURNS AND PAMELA BURNS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21995-94. Filed February 19, 1997.
Peter Ambelang, for petitioners.
Susan E. Seabrook, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All
section references are to the Internal Revenue Code in effect for
the year in issue. All Rule references are to the Tax Court
Rules of Practice and Procedure.
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