T.C. Memo. 1999-79
UNITED STATES TAX COURT
RICHARD L. AND KATHRYN DYCKMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24248-95. Filed March 12, 1999.
Richard L. and Kathryn Dyckman, pro sese.
Louise R. Forbes and John R. Mikalchus, 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 year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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