T.C. Memo. 1997-386
UNITED STATES TAX COURT
ROBERT R. PLANTE AND MARY B. PLANTE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24341-95. Filed August 25, 1997.
Thomas A. Lawler, for petitioners.
Albert B. Kerkhove, for respondent.
MEMORANDUM OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. Unless otherwise indicated, section references are to the
Internal Revenue Code in effect during the relevant year. Rule
references are to the Tax Court Rules of Practice and Procedure.
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