T.C. Memo. 1997-328
UNITED STATES TAX COURT
DAVID DANIEL AND ANNETTE DANIEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7427-96. Filed July 21, 1997.
Keith Howard Johnson, for petitioners.
Francis C. Mucciolo, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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