T.C. Memo. 1998-372
UNITED STATES TAX COURT
GREGORY STEWART MALONE AND PAMELA JOYCE MALONE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24609-97. Filed October 13, 1998.
Gregory Stewart Malone and Pamela Joyce Malone, pro sese.
James F. Prothro, for respondent.
MEMORANDUM OPINION
COHEN, Chief Judge: This case was assigned to Special Trial
Judge John F. Dean pursuant to section 7443A(b)(4) and Rules 180,
181, and 183.1 The Court agrees with and adopts the opinion of
the Special Trial Judge, which is set forth below.
1All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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