T.C. Memo. 1998-398
UNITED STATES TAX COURT
BENJAMIN B. AND DORINA MICORESCU, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24964-96. Filed November 10, 1998.
Douglas G. Miller, for petitioners.
Ann M. Murphy, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent
determined deficiencies in petitioners' Federal income taxes for
1Unless otherwise indicated, all 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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