T.C. Memo. 1999-113
UNITED STATES TAX COURT
CLAIR AND JUDITH WORTHINGTON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22005-97. Filed April 5, 1999.
Clair and Judith Worthington, pro sese.
Brian Bernhardt, for respondent.
MEMORANDUM OPINION
WOLFE, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. All section references are to the Internal Revenue Code in
effect for the tax years in issue, unless otherwise indicated.
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