T.C. Memo. 1998-274
UNITED STATES TAX COURT
DAVID R. GREEN AND CAROLYN B. GREEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8933-94, 6564-96, Filed July 27, 1998.
26100-96.
W. Kevin Jackson, for petitioners.
S. Mark Barnes, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: These consolidated cases were
heard pursuant to section 7443A(b)(3) of the Code and Rules 180,
181, and 182. All section references are to the Internal Revenue
Code in effect for the years in issue. All Rule references are
to the Tax Court Rules of Practice and Procedure. Respondent
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