T.C. Memo. 1999-28
UNITED STATES TAX COURT
TIM R. CASANOVA AND SAN JUANITA VILLAREAL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10605-98. Filed February 1, 1999.
Tim R. Casanova and San Juanita Villareal, pro sese.
Melinda G. Williams and James G. Macdonald, for respondent.
MEMORANDUM OPINION
COHEN, Chief Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., 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, which is set
forth below.
1 All section references are to the Internal Revenue Code,
as amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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