T.C. Memo. 1998-249
UNITED STATES TAX COURT
EARL M. HASBROUCK AND DONNA M. HASBROUCK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10964-96. Filed July 7, 1998.
Earl M. Hasbrouck and Donna M. Hasbrouck, pro sese.
Joan S. Dennett, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was assigned
pursuant to section 7443A(b)(3) of the Internal Revenue Code, as
amended and in effect when the petition was filed, and Rules 180,
181, and 182. Unless otherwise indicated, section references are
to the Internal Revenue Code, as amended and in effect for the
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