T.C. Memo. 1997-267
UNITED STATES TAX COURT
JAMES C. AND JANE A. WETZEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20871-95. Filed June 12, 1997.
Donald J. O'Connor, for petitioners.
Marc A. Shapiro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
POWELL, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1
1 All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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