T.C. Memo. 1999-230
UNITED STATES TAX COURT
CHARLES A. AND CAROL M. WILLITS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15559-97. Filed July 13, 1999.
Dan S. Maccabee, for petitioners.
Lisa Primavera, for respondent.
MEMORANDUM OPINION
NAMEROFF, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
Respondent determined deficiencies in petitioners’ 1992 and
1993 Federal income taxes in the amounts of $3,570 and $8,526,
1 Unless otherwise specified, all section references are to
the Internal Revenue Code in effect for the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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