T.C. Memo. 1998-182
UNITED STATES TAX COURT
CARL W. AND BARBARA H. PATTERSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10583-96. Filed May 18, 1998.
Carl W. Patterson and Barbara H. Patterson, pro sese.1
Gregory M. Hahn, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.2
1 At the trial of this case, petitioners were represented by
Robert E. Kovacevich, an attorney admitted to practice before
this Court. After trial, however, Mr. Kovacevich was granted
leave to withdraw as counsel, and petitioners filed their brief
on a pro se basis.
2 Unless otherwise indicated, all section references are to
(continued...)
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