T.C. Memo. 1999-236
UNITED STATES TAX COURT
GARY G. AND LINDA J. HART, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5492-98. Filed July 21, 1999.
Gary R. Matthews, for petitioners.
Aubrey C. Brown, 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
(continued...)
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