T.C. Memo. 1998-425
UNITED STATES TAX COURT
RICHARD J. AND ANNA J. SINSIGALLI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
Docket Nos. 18130-97, 13107-98. Filed November 25, 1998.
Richard J. and Anna J. Sinsigalli, pro se.
Richard A. Stone, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: These consolidated cases were
heard pursuant to the provisions of section 7443A(b)(3) and Rules
180, 181, and 182.1
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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