T.C. Memo. 1997-370
UNITED STATES TAX COURT
MERRELL AND FRANCINE VANNIER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18536-95. Filed August 13, 1997.
Merrell Vannier, pro se.
Gregory J. Powers, for respondent.
MEMORANDUM OPINION
NAMEROFF, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and
182. Respondent determined a deficiency in petitioners’ 1991
1 Unless otherwise indicated, all 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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