T.C. Memo. 2004-276
UNITED STATES TAX COURT
JAMES G. AND LINDA C. JAROFF, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19193-99. Filed December 8, 2004.
Steven D. Morford, for petitioners.
Nhi T. Luu-Sanders, for respondent.
MEMORANDUM OPINION
WOLFE, Special Trial Judge: This case was assigned pursuant
to the provisions of section 7443A(b)(5) in effect when these
proceedings commenced, and Rules 180, 181, and 183. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect at relevant times, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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