T.C. Memo. 1997-378
UNITED STATES TAX COURT
RICHARD G. AND PATRICIA A. COOK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26918-95. Filed August 19, 1997.
Richard G. Cook, pro se.
David W. Sorensen, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the years at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure. The petition was filed pursuant to sec. 7463. At the
commencement of trial, petitioners orally moved that the case be
heard pursuant to sec. 7443A(b)(3). The Court granted
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