T.C. Memo. 1997-318
UNITED STATES TAX COURT
LEONARD CHARLES AND KAYE LAYNE EKMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1920-95. Filed July 9, 1997.
Paul Croushore, for petitioners.
James W. Ruger, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.
Respondent determined a deficiency of $2,925 in petitioners'
Federal income tax for 1991. The issues for decision are:
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the year at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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