T.C. Memo. 1998-119
UNITED STATES TAX COURT
WILLIAM AND ARLENE G. KINGSTON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15409-95. Filed March 25, 1998.
William and Arlene G. Kingston, pro se.
Elizabeth Flores, for respondent.
MEMORANDUM OPINION
WELLS, Judge: This case was assigned to Special Trial Judge
D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules
180, 181, and 183. The Court agrees with and adopts the opinion
of the Special Trial Judge, which is set forth below.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code. All Rule references are to the Tax Court
Rules of Practice and Procedure.
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