T.C. Memo. 1997-333
UNITED STATES TAX COURT
THOMAS H. AND MAUREEN HESSE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3448-97. Filed July 23, 1997.
K. Layne Morrill (specially recognized), for petitioners.
Richard A. Rappazzo, for respondent.
MEMORANDUM OPINION
ARMEN, 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, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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