T.C. Memo. 2003-100
UNITED STATES TAX COURT
MICHAEL THOMAS PRASIL AND LORI LYNN PRASIL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3945-02. Filed April 9, 2003.
Michael Thomas Prasil and Lori Lynn Prasil, pro sese.
Kathryn F. Patteron and Douglas R. Fortney, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7443A(b)(3)1 and Rules 180, 181, and
182 of the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners’
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 1999,
the taxable year in issue.
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