T.C. Memo. 1999-191
UNITED STATES TAX COURT
RONALD D. AND SHIRLEY A. BLUSH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3637-98. Filed June 10, 1999.
David A. Slacter, for petitioners.
William J. Gregg, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.
1
Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the years in issue.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
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