T.C. Memo. 1997-41
UNITED STATES TAX COURT
KENNETH C. AND ELAINE SCHMIDT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2882-96. Filed January 23, 1997.
Mark Kutschenreuter, for petitioners.
James E. Schacht, for respondent.
MEMORANDUM FINDINGS OF FACT AND 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 in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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