T.C. Memo. 1998-266 UNITED STATES TAX COURT TOM AND BRENDA KELLY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21641-96. Filed July 21, 1998. Tom Kelly, pro se. Thomas C. Pliske, 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 Practice and Procedure.Page: 1 2 3 4 5 Next
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