T.C. Memo. 1998-244
UNITED STATES TAX COURT
MICHAEL E. AND NANCY HENTGES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11049-96. Filed July 6, 1998.
James A. Hogue and James O. Goodwin, for petitioners.
William F. Castor, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7443A(b)1 and Rules 180, 181, and 182.
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the year at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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