T.C. Memo. 1998-462
UNITED STATES TAX COURT
PRESTON L. AND RUBY M. PAYTON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5405-97. Filed December 30, 1998.
Ruby M. Payton, pro se.
Roger W. Bracken, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) and Rules 180, 181, and 182. All section
references are to the Internal Revenue Code in effect for the
years in issue. All Rule references are to the Tax Court Rules
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