T.C. Memo. 1998-158
UNITED STATES TAX COURT
ROBERT C. FORS AND LUCILLE FORS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4868-97. Filed April 30, 1998.
Robert C. Fors, pro se.
John C. Schmittdiel, for respondent.
MEMORANDUM OPINION
DINAN, 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 year in
issue. All Rule references are to the Tax Court Rules of
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