T.C. Memo. 1998-437
UNITED STATES TAX COURT
JEFFREY C. AND KELLY O. STONE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3812-97. Filed December 14, 1998
Jeffrey C. and Kelly O. Stone, pro se.
Joan S. Dennett, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with
and adopts the opinion of the Special Trial Judge that is set
forth below.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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