T.C. Memo. 1999-39
UNITED STATES TAX COURT
DAN PISTORESI AND ELAINE M. PISTORESI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24774-96. Filed February 8, 1999.
Dan Pistoresi, pro se.
Ralph W. Jones, for respondent.
MEMORANDUM OPINION
DINAN, 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. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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