Gerard and Audrey Kathleen Hennessey - Page 2




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          indicated, section references are to sections of the Internal               
          Revenue Code in effect at all relevant times hereunder.                     
          References to section 7430 are to the version of that section in            
          effect at the time the petition was filed.  However, costs                  
          incurred on or before January 18, 1999, are subject to section              
          7430 as amended by the Taxpayer Relief Act of 1997, Pub. L. 105-            
          34, secs. 1285, 1453, 111 Stat. 1038, 1055.  Costs incurred after           
          January 18, 1999, are subject to section 7430 as amended by the             
          Internal Revenue Service Restructuring and Reform Act of 1998               
          (RRA 1998), Pub. L. 105-206, sec. 3101, 112 Stat. 727.                      
               Rule references are to the Tax Court Rules of Practice and             
          Procedure.                                                                  
               Pursuant to section 7443A and Rules 180 and 183, this matter           
          was assigned to and heard by Special Trial Judge Lewis R.                   
          Carluzzo.  His recommended findings of fact and conclusions of              
          law were filed and served upon the parties by Order of July 5,              
          2005.                                                                       
               By the abovementioned Order, the parties were also given               
          until August 31, 2005, to make specific written objections to the           
          Special Trial Judge’s recommended findings of fact and                      
          conclusions of law.  In response thereto, respondent filed a                
          timely Notice of No Objection.  Petitioners timely filed 26 pages           
          of Objections to Recommendations (Objections).                              








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