T.C. Memo. 1997-480
UNITED STATES TAX COURT
HARRY E. THOMASON AND ESTATE OF HATTIE D. THOMASON, DECEASED,
MARY T. CRIST, PERSONAL REPRESENTATIVE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8746-95. Filed October 22, 1997.
John R. Foley, for petitioners.
Leslie H. Finlow, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1
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.
After the petition was filed, petitioner Hattie D. Thomason died,
and her daughter, Mary T. Crist, personal representative of the
estate of Hattie D. Thomason, was substituted on behalf of the
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