T.C. Memo. 2003-238
UNITED STATES TAX COURT
LAWRENCE S. AHMAOGAK AND MYRNA AHMAOGAK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10850-01. Filed August 11, 2003.
Mason D. Morisset, for petitioners.
Lisa M. Oshiro, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Lewis R. Carluzzo pursuant to section 7443A(b)(5) and Rules
180, 181, and 183.1 The Court agrees with and adopts the opinion
of the Special Trial Judge, which is set forth below.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code of 1986, as amended. Rule references are
to the Tax Court Rules of Practice and Procedure.
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