T.C. Memo. 1999-249 UNITED STATES TAX COURT STEVEN D. RAPP AND JUDITH A. RAPP, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18039-97. Filed July 28, 1999. Scott M. Nelson and Robert B. Patterson, for petitioners. Blaine C. Holiday, 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 years in (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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