T.C. Memo. 1998-238
UNITED STATES TAX COURT
NICHOLAS M. ROMER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8352-97. Filed July 2, 1998.
Howard S. Kleyman, for petitioner.
Tracy A. Martinez and Jonathan Decatorsmith, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
issue. All Rule references are to the Tax Court Rules of
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