T.C. Memo. 1998-384                                  
                               UNITED STATES TAX COURT                                
                 CLIFFORD THOMAS AND LEAH DIANE NOAH, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 27259-96.                 Filed October 26, 1998.           
               Clifford Thomas Noah and Leah Diane Noah, pro sese.                    
               T. Richard Sealy III and Lewis J. Hubbard, Jr., for                    
          respondent.                                                                 
                                 MEMORANDUM OPINION                                   
               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A and Rules 180, 181, and 182.1            
               Respondent determined deficiencies in petitioners' Federal             
          1  Unless 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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