T.C. Memo. 1998-351
UNITED STATES TAX COURT
DON AND MARGARET TAYLOR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21611-97. Filed October 5, 1998.
Noel Bisges, for petitioners.
Douglas Polsky, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, 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 years in
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