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...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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