T.C. Memo. 1999-251
UNITED STATES TAX COURT
RENEE B. SIMPSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16789-97. Filed July 29, 1999.
Frederich Earl Liechti, for petitioner.
John M. Zoscak, Jr., for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case was heard pursuant to
section 7443A(b)(3) and Rules 180, 181, and 182.1
1Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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