T.C. Memo. 1997-198
UNITED STATES TAX COURT
GEORGE A. AND MARYSUE COWARD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22986-89. Filed April 30, 1997.
Steven B. Jacobs, for petitioners.
Alan E. Staines, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was assigned
pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1
Respondent determined deficiencies in, and additions to
petitioners' Federal income taxes as follows:
1 Unless otherwise indicated, all 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.
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