T.C. Memo. 1998-165
UNITED STATES TAX COURT
JOHN H. & MARY E. DOUGLAS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21113-96. Filed May 6, 1998.
John H. Douglas, pro se.
Gregory S. Matson, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 Respondent determined deficiencies in
1 All section references are to the Internal Revenue Code
in effect for the years in issue, unless otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
(continued...)
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