RYALL v. COMMISSIONER

Docket No. 15392-88.

63 T.C.M. 2139 (1992)

T.C. Memo. 1992-103

Robert W. Ryall and Margit Ryall v. Commissioner.

United States Tax Court.

Filed February 19, 1992.


Attorney(s) appearing for the Case

Mark E. Gammons, for the petitioners. Dawn M. Krause, for the respondent.


Memorandum Findings of Fact and Opinion

PETERSON, Chief Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.

Respondent determined a deficiency in petitioners' income tax, increased interest, and additions to tax as follows...

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