T.C. Memo. 1999-54 UNITED STATES TAX COURT KARL T. HARVEY AND KATHLEEN S. HARVEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14541-97. Filed February 26, 1999. Steven M. Cyr, for petitioners. Ann M. Murphy, for respondent. MEMORANDUM OPINION DINAN, Special Trial Judge: This case was submitted 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 issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 Next
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