T.C. Memo. 1998-301
UNITED STATES TAX COURT
ROBERT AND DIANA ROBERTS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22985-97. Filed August 19, 1998.
Edward A. Rose, Jr., for petitioners.
T. Ian Russell, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos, pursuant to the provisions of
section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court
1
Unless otherwise indicated, all section references are
to the Internal Revenue Code. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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