§7443 Membership — Athena Tax

OVERRULED Cinema '84; Richard M. Greenberg, Tax Matters Partner, Petitioners 122 T.C. No. 13 · 2004

128 (1971), is overruled and will no longer be followed because of the Supreme Court decision.

DIST. Lonnie Wayne Hubbard, Petitioner T.C. Memo. 2024-16 · 2024

Specifically, petitioner argues that Carione is inapposite to the present case because the taxpayer in Carione willfully sold his business and then applied the sale proceeds toward a criminal forfeiture.

DIST. Ervin Michael Sarrell, Petitioner 117 T.C. No. 11 · 2001

Further, unlike sec. 6213(a), I.R.C., which is applicable to deficiency actions, sec. 6330, I.R.C., does not provide an expanded filing period when a notice of determination is addressed to a person outside the United States. Ervin Michael Sarrell, pro se. William J. Gregg, for respondent. OPINION DAWSON, Judge: This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the o

FOLLOWED Joseph Thomas Lander & Kimberly W. Lander, Petitioners · 2020

OPINION GOEKE, Judge: This case was assigned to and trial was conducted by Special Trial Judge Guy pursuant to section 7443A(b)(4)¹ and Rules 182(e) and 183.

FOLLOWED Timothy Lee Richard, Petitioner & Susan Lynn Ellis, Intervenor, Petitioners T.C. Memo. 2011-144 · 2011

MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Chief Jùdge: Pursuant to section 7443A arid Rules 180 arid 183, I this case was assigned to and heard by Special a 3 ItJnliess otherwise indicated,.

FOLLOWED Robert Ancira, Petitioner 119 T.C. No. 6 · 2002

Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

FOLLOWED Stephen T. & Landa C. Fan, Petitioner 117 T.C. No. 3 · 2001

Carluzzo pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

FOLLOWED Kathy A. King, Petitioner and Curtis T. Freeman, Intervenor, Petitioners 116 T.C. No. 16 · 2001

Irvin Couvillion pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

FOLLOWED Walter R. Strohmaier, Petitioner 113 T.C. No. 5 · 1999

Irvin Couvillion pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

FOLLOWED Robert & Linda Yuen, Petitioner 112 T.C. No. 12 · 1999

Panuthos pursuant to section 7443A(b)(4) 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.

FOLLOWED Herbert C. Elliott, Petitioner 113 T.C. No. 7 · 1999

Held: Because the Form 1040 submitted on behalf of P was not signed as required by sec.

FOLLOWED Dennis L. & Sharon E. Hayden, Petitioner 112 T.C. No. 11 · 1999

Powell pursuant to section 7443A(b)(3) and - 2 - Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

FOLLOWED Richard Leo Warbus, Petitioner 110 T.C. No. 21 · 1998

Dean pursuant to section 7443A(b) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

FOLLOWED Thomas L. Freytag & Sharon N. Freytag, Petitioners 110 T.C. No. 5 · 1998

Held: This Court has jurisdiction. Comas, Inc. v. Commissioner, 23 T.C. 8 (1954), and Valley Die Cast Corp. v. Commissioner, T.C. Memo. 1983-103, distinguished. Held, further, the period of limitations for making an assessment has not expired. Held, further, under the principles of res judicata a decision will be entered consistent with the determinations of the bankruptcy court.

FOLLOWED Therese Hahn, Petitioner 110 T.C. No. 14 · 1998

Dean pursuant to section 7443A(b)(4) 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.

FOLLOWED Guillermo Baez Espinosa, Petitioner 107 T.C. No. 9 · 1996

Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

John E. Hunter, II & Alma E. Hunter, Petitioners T.C. Memo. 2007-23 · 2007

MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Pursuant to section 7443A and Rules 180 and 183, these cases were assigned to and heard by Chief Special - 2 - Trial Judge Peter J.

Gerard & Audrey Kathleen Hennessey, Petitioner T.C. Memo. 2007-131 · 2007

Pursuant to section 7443A and Rules 180 and 183, this matter was assigned to and heard by Special Trial Judge Lewis R.

John Erwin Hunter, II, Petitioner T.C. Memo. 2007-23 · 2007

MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge : Pursuant to section 7443A and Rules 180 and 183, these cases were assigned to and heard by Chief Special FEB - 5 2001 SERVED as 2 - Trial Judge Peter J.

Charles McHan and Martha McHan, Petitioners T.C. Memo. 2006-84 · 2006

MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, Judge: Pursuant to section 7443A and Rules 180 and 183,1 this case was assigned to and heard by Special Trial Judge 1 Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Claire C. Meade, Petitioner and James W. Meade, Intervenor, Petitioners T.C. Memo. 2006-209 · 2006

Panuthos pursuant to section 7443A(b) (6)¹ and Rules 180 and 183..

Cynthia Emery Weight, Petitioner T.C. Memo. 2003-214 · 2003

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.

Lawrence S. & Myrna Ahmaogak, Petitioner T.C. Memo. 2003-238 · 2003

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.

Ronald McLean Eastern Video, Petitioner T.C. Memo. 2003-13 · 2003

Dean 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.

H & H Trim & Upholstery Co., Inc., Petitioner T.C. Memo. 2003-9 · 2003

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.

George N. & Maggie Ahmaogak, Petitioner T.C. Memo. 2003-220 · 2003

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.

Harold F. Behling, Petitioner 118 T.C. No. 36 · 2002

Held: Because P received the deficiency notice and had an opportunity to dispute R’s determination, P is statutorily barred from challenging the existence or amount of his liability in this proceeding. Sec. 6330(c)(2)(B), I.R.C. The fact that R’s Appeals officer considered the merits of the loss at the administrative hearing and the further fact that the notice of determination addressed those merits do not constitute a waiver of the statutory bar. Held, further, sec. 301.6320-1(e)(3), Q&A-E11,

John J. Petito, Petitioner T.C. Memo. 2002-271 · 2002

Panuthos pursuant to section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended; references to sec.

Billye S. Cannon, Petitioner T.C. Memo. 2002-205 · 2002

Carluzzo pursuant to section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion 1 Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended and in effect at the time that the petition was filed.

James K. Gaudet, Petitioner T.C. Memo. 2001-309 · 2001

Powell pursuant to section 7443A(b)(5) and Rules 180, 181, and 183.

Madison Recycling Associates; David A. Beldon, Robert T. Boyd, Douglas C. Brandon, Stewart Pierce Brown, Lloyd E. Busch, David J. D'Antoni, John H.Delaney, Jr., Daniel C. Greer, Gerald O. Henderson, Charles D. Hoertz,Estate of Joseph Kessel, Thomas P. Korehle, Josiah O. Low, III, Robert J.Ripston, Howard S. Siever, Lavonne F. Siever, James W. Simpson, Jr., R.BarryUber, Lillian D. Williams, Partners Other Than The Tax Matters Partner, Petitioners T.C. Memo. 2001-85 · 2001

Carluzzo pursuant to section 7443A(b)(5) and Rules SERVED APR 9 2001 - 2 - 180, 181, and 183.¹ The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

James Triplett, Petitioner T.C. Memo. 2001-320 · 2001

Carluzzo pursuant to section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, in effect at the time the petition was filed in this case, and Rules 180, 181, and 183 of the Tax Court Rules of Practice and Procedure.

Bruce A. & Kathy J. Krist, Petitioner T.C. Memo. 2001-140 · 2001

MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge: This case was assigned to Special Trial Judge Pajak pursuant to section 7443A(b)(4), Internal Revenue Code in effect when the petition was filed, and Rules 180, 181, and 183, Tax Court Rules of Practice and Procedure.

Larry D. & Gail Scott, Petitioner T.C. Memo. 2000-369 · 2000

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.

William M. Donovan, Petitioner T.C. Memo. 2000-220 · 2000

Carluzzo pursuant to section 7443A(b)(4) 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.

Michael F. & Jane H. Connor, Petitioner T.C. Memo. 1999-185 · 1999

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Thomas J. & Robin Havens, Petitioner T.C. Memo. 1999-128 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to (continued...) - 2 - Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1995 in the amount of $582.

A. Muhsin & B. Jackson Muhsin, Petitioners T.C. Memo. 1999-215 · 1999

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Irv C. Jaffe, Petitioner T.C. Memo. 1999-196 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION - 2 - COUVILLION, Special Trial Judge: These consolidated cases 1 were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Don Laverne Clarke, Petitioner T.C. Memo. 1999-199 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to (continued...) - 2 - Respondent determined a deficiency in petitioner's Federal income tax for the year 1993 in the amount of $1,005.

Linda M. Klyce, Petitioner T.C. Memo. 1999-198 · 1999

MEMORANDUM OPINION COUVILLION, Special Trial Judge: These consolidated cases 1 were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Ronald D. & Shirley A. Blush, Petitioner T.C. Memo. 1999-191 · 1999

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Said Mahmoud Karara, Petitioner T.C. Memo. 1999-253 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION COUVILLION, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Humes Houston Hart, Petitioner T.C. Memo. 1999-186 · 1999

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Paul F. & Sherry L. Dickie, Petitioner T.C. Memo. 1999-138 · 1999

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Vincent E. & Judy Bot, Petitioner T.C. Memo. 1999-256 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

David J. & Patricia A. Fogderud, Petitioner T.C. Memo. 1999-13 · 1999

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Daniel Francis Kelly, Jr., Petitioner T.C. Memo. 1999-69 · 1999

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Chrys L. Udoh, Petitioner T.C. Memo. 1999-174 · 1999

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Renee B. Simpson, Petitioner T.C. Memo. 1999-251 · 1999

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue.

Thomas Mark Peaslee, Petitioner T.C. Memo. 1999-4 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Internal Revenue Code and Rules 180, 181, and 182 of the Tax Court Rules of Practice and Procedure.

Terry U. Neal, Petitioner T.C. Memo. 1999-97 · 1999

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b) (3) and Rules 180, 181, and 182.

Arlene K. Jaffe, Petitioner T.C. Memo. 1999-196 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION - 2 - COUVILLION, Special Trial Judge: These consolidated cases 1 were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Paul M. & June S. Sengpiehl, Petitioner T.C. Memo. 1998-23 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for 1991 in the amount of $4,828.

Loretta Manukainiu, Petitioner T.C. Memo. 1998-90 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

David R. Green & Carolyn B. Green, Petitioners T.C. Memo. 1998-274 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Antonino & Francesca Pecora, Petitioner T.C. Memo. 1998-393 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Michael J. Heckler, a.k.a. Michael VonHeckler & Charlotte A. Miska, Petitioners T.C. Memo. 1998-49 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Denson C. & Linda C. Brumley, Petitioner T.C. Memo. 1998-424 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 In a notice of deficiency dated April 23, 1997, respondent determined a deficiency in petitioners’ Federal income tax for the taxable 1 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedur

William & Arlene G. Kingston, Petitioner T.C. Memo. 1998-119 · 1998

Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183.

Estate of Doris J. Severt, Deceased; Denise M. Harple, Executor, Petitioners T.C. Memo. 1998-34 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in Doris J.

Benjamin B. & Dorina Micorescu, Petitioner T.C. Memo. 1998-398 · 1998

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes for 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Robert P. & Sally A. Neumann, Petitioner T.C. Memo. 1998-126 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Daniel E. Godfrey, Petitioner T.C. Memo. 1998-51 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $751.

Marian & Halina Januszewski, Petitioner T.C. Memo. 1998-390 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Mehran Etesam, Petitioner T.C. Memo. 1998-73 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency and an addition to tax under section 6651(a) in petitioner's 1993 Federal income tax in the respective amounts of $425 and $396.05.

Joe T. & Linda R. Kieffer, Petitioner T.C. Memo. 1998-202 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1993 and 1994 in the amounts of $1,873 and 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Frances L. & Gary L. Rambacher, Petitioner T.C. Memo. 1998-124 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined additions to petitioners’ Federal income tax for the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Dale Reid Edmonds, Petitioner T.C. Memo. 1998-379 · 1998

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

James J. & Linda J. Harford, Petitioner T.C. Memo. 1998-392 · 1998

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Michael E. & Nancy Hentges, Petitioner T.C. Memo. 1998-244 · 1998

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)1 and Rules 180, 181, and 182.

W. Gregory & Patricia L. Ryan, Petitioner T.C. Memo. 1998-331 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: These cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 These 1Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue, and Rule (continued...) - 2 - cases were consolidated on August 20, 1997, for purposes of trial, briefing, and opinion.

Michael & Christa Dee Richardson, Petitioner T.C. Memo. 1998-236 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Lester Johnson & Sherelle D. Brooks-Johnson, Petitioners T.C. Memo. 1998-171 · 1998

Nameroff pursuant to section 7443A(b) and Rules - 2 - 180, 181, 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Benjamin H. Smith, Petitioner T.C. Memo. 1998-33 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Gerald P. & Abbe L. Keane, Petitioner T.C. Memo. 1998-116 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

Dean Scott Hodge, Petitioner T.C. Memo. 1998-242 · 1998

MEMORANDUM OPINION COUVILLION, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, 1 and 182.

Preston L. & Ruby M. Payton, Petitioner T.C. Memo. 1998-462 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Randal W. Howard, Petitioner T.C. Memo. 1998-57 · 1998

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Gregory Stewart & Pamela Joyce Malone, Petitioner T.C. Memo. 1998-372 · 1998

Dean pursuant to section 7443A(b)(4) 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.

Ludivina Madrigal, Petitioner T.C. Memo. 1998-345 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A of the Code and Rules 180, 181, and 182 of the Tax Court Rules of Practice and Procedure.

Leslie A. & Betsy M. Roy, Petitioner T.C. Memo. 1998-125 · 1998

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes for the years 1992 and 1993 in the amounts of $3,600 and $3,901, 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court

Bonnie A. Broughton, Petitioner T.C. Memo. 1998-409 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was assigned pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1994 and 1995 in the respective amounts of $735 and $752.

John Andrew & Donna L. Dorris, Petitioner T.C. Memo. 1998-324 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

David R. & Carolyn B. Green, Petitioner T.C. Memo. 1998-274 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Theodore Jones, Petitioner T.C. Memo. 1998-197 · 1998

The issue for decision is whether petitioners filed their separate petitions within the 90-day period 2 prescribed by section 6213(a).1 The motions were assigned for hearing pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.

David R. & Carolyn B. Green, Petitioner T.C. Memo. 1998-274 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Ronald R. & Cathy L. Armacost, Petitioner T.C. Memo. 1998-150 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in Ronald and Cathy Armacost's Federal income taxes for the taxable year 1992 in the amount of $5,470.

Earl M. & Donna M. Hasbrouck, Petitioner T.C. Memo. 1998-249 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was assigned pursuant to section 7443A(b)(3) of the Internal Revenue Code, as amended and in effect when the petition was filed, and Rules 180, 181, and 182.

Bernard Boozer, Petitioner T.C. Memo. 1998-446 · 1998

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Astrida Terauds, Petitioner T.C. Memo. 1997-64 · 1997

Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183.

Lucine Williams, Petitioner T.C. Memo. 1997-540 · 1997

Nameroff pursuant to section 7443A(b)(4) and Rules - 2 - 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Elizabeth H. & Albert B. Turner, Petitioner T.C. Memo. 1997-522 · 1997

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Richard G. & Patricia A. Cook, Petitioner T.C. Memo. 1997-378 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue.

Jennifer A. Lestrange, Petitioner T.C. Memo. 1997-428 · 1997

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code, and Rules 180, 181, and 182.

Simon J. Trueblood, Petitioner T.C. Memo. 1997-524 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 This case is before the Court on petitioner's motion to vacate the granting on November 5, 1996, of respondent's Motion to Dismiss for Lack 1 All section references are to the Internal Revenue Code in effect for the years in issue.

Robin Adams, Petitioner T.C. Memo. 1997-111 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's 1990 and 1991 Federal income taxes in the respective amounts of $3,529 and $3,694.

Raymond Verni Schroeder, Petitioner T.C. Memo. 1997-517 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Kathie J. Smee, f.k.a. Kathie J. Zavitz, Petitioners T.C. Memo. 1997-364 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter is before the Court on the motion to stay proceedings filed by petitioner Kathy J.

Richard Walter Drake, Petitioner T.C. Memo. 1997-487 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

George A. & MarySue Coward, Petitioner T.C. Memo. 1997-198 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was assigned pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 Respondent determined deficiencies in, and additions to petitioners' Federal income taxes as follows: 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue.

Eli & Karen Yecheskel, Petitioner T.C. Memo. 1997-89 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Richard W. Kochansky & Monica L. Miller, f.k.a. Monica L. Kochansky, Petitioners T.C. Memo. 1997-192 · 1997

Irvin Couvillion pursuant to section 7443A(b)(4)and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Joe E. & Carolyn J. Henry, Petitioner T.C. Memo. 1997-86 · 1997

Carluzzo pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.

Richard John Kadunc, Petitioner T.C. Memo. 1997-92 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Curtis G. & Edna L. Lockett, Petitioner T.C. Memo. 1997-107 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)I and Rules 180, 181, and 182.

Lindley Anthony Swanston, Petitioner T.C. Memo. 1997-103 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Richard A. & Janice S. Adams, Petitioner T.C. Memo. 1997-357 · 1997

Powell pursuant to section 7443A(b)(4) and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

William & Arlene G. Kingston, Petitioner T.C. Memo. 1997-512 · 1997

Irvin Couvillion pursuant to section 7443A(b)(4) 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.

Charles T. & Bettye Gilmore, Petitioner T.C. Memo. 1997-174 · 1997

Carluzzo pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.

John J. McMahon, Petitioner T.C. Memo. 1997-568 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and (continued...) - 2 - Respondent determined a deficiency in petitioners James and Barbara Brooks' 1993 Federal inc

Harry E. Thomason and Estate of Hattie D. Thomason, Deceased, Mary T. Crist, Personal Representative, Petitioners T.C. Memo. 1997-480 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Stanley & Gail Laber, Petitioner T.C. Memo. 1997-559 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners’ Federal income tax for 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

William J. Tully, Petitioner T.C. Memo. 1997-310 · 1997

Nameroff pursuant to section 7443A(b)and Rules 181 - 2 - and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Donald A. Robins, Petitioner T.C. Memo. 1997-245 · 1997

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code, and Rules 180, 181, and 182.

Julie Pusateri, Petitioner T.C. Memo. 1997-7 · 1997

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

O. H. Tolley, Jr. & Betty Tolley, Petitioners T.C. Memo. 1997-244 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Peter M. Schaeffer, Petitioner T.C. Memo. 1997-263 · 1997

Nameroff pursuant to section 7443A(b)and Rules - 2 - 180, 181 and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Derk O. & Julia K. Pehrson, Petitioner T.C. Memo. 1997-344 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Amarillo Council on Alcoholism and Drug Abuse, Petitioner T.C. Memo. 1997-518 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.2 1 Cases of the following petitioners are consolidated herewith for purposes of trial, briefing and opinion: Family Service of El Paso, Inc., docket No.

Mary Ann & Wilson R. Collins, Petitioner T.C. Memo. 1997-129 · 1997

Irvin Couvillion pursuant to section 7443A(b)(4) and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Alton W. & Pamela Burns, Petitioner T.C. Memo. 1997-83 · 1997

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Leonard Charles & Kaye Layne Ekman, Petitioner T.C. Memo. 1997-318 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Vena Marilyn Wofford, Petitioner T.C. Memo. 1997-62 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: The case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

Estate of Romine C. Hogard, Deceased, James C. Elliott, and Bill F. Stewart, Co-Personal Representatives, and Wanda L. Hogard, Petitioners T.C. Memo. 1997-174 · 1997

Carluzzo pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.

Sharon E. Backstrom; Harold J. & Zelma G. Barbret; Virginia Boland; John A. & Theresa A. Cislaghi; Estate of Roger W. Dornbrock, Deceased; Maryn J. Dornbrock, Personal Representative; Maryn J. Dornbrock; Gary E. & Beverly G. Engel; Hermann K. & Helen W. Enzmann; Don & Mary Everett; Kenneth B. & Mary J.Faust; Estate of Harold E. Frazer, Deceased; Elizabeth Frazer, Personal Representative; Charlotte V. Frazer; William M. & Martha J. Goodman; Paul W. & Kathleen M. Hammer; John & Rita C. Harvey; William R. & Ethel Kelley; Edward& Arles Kogelman; Terrence L. Labadie; Frances Eng Lee; George R. Martell; Craig A. & Cynthia M. Peltier; Myra Joan Rodgers; William H. & Shirley M. Shaw; Karl L. & Sui Ti A. Siebert; John M. & Sandra Soper; Paul J. & Nancy L. Spindler; Gerard W. J. & Madeline Tremblay; Richard R. & Monica J. Riddle; Carol T. Jakubowski; and Arthur Miller, Petitioners T.C. Memo. 1997-211 · 1997

Irvin Couvillion pursuant to section 7443A(b)(4)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.

Keith Lee Wilson, Petitioner T.C. Memo. 1997-515 · 1997

Nameroff pursuant to section 7443A(b)(4)and Rules - 2 - 180, 181 and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Octavio & Felicitas Olvera, Petitioner T.C. Memo. 1997-488 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes for 1993 and 1994 in the respective amounts of $498 and $1,261.

Donald S. Hazelton, Petitioner T.C. Memo. 1997-66 · 1997

Irvin Couvillion pursuant to section 7443A(b)(4)and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Collin L. Dugan, Petitioner T.C. Memo. 1997-458 · 1997

Carluzzo pursuant to section 7443A(b)(4) of the Internal Revenue Code, as amended, and Rules 180, 181, and 183 of - 2 - the Tax Court Rules of Practice and Procedure.

Women of the Motion Picture Industry, Petitioner T.C. Memo. 1997-518 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.2 1 Cases of the following petitioners are consolidated herewith for purposes of trial, briefing and opinion: Family Service of El Paso, Inc., docket No.

Joseph Baldwin Campbell, Petitioner T.C. Memo. 1997-502 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Jerome V. Mancebo, Petitioner T.C. Memo. 1997-46 · 1997

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Marvin Ziporyn, Petitioner T.C. Memo. 1997-151 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: The case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

Gerry Dan & Kelly M. Langston, Petitioner T.C. Memo. 1997-303 · 1997

The motion was assigned for hearing - 2 - pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183.

Kenneth C. & Becky J. Theisen, Petitioner T.C. Memo. 1997-539 · 1997

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

William L. & Mary Lee Powell, Petitioner T.C. Memo. 1997-560 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction.

Diane Cameron Horton, Petitioner T.C. Memo. 1997-572 · 1997

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code, and Rules 180, 181, and 182.

Anthony J. McCarthy, Petitioner T.C. Memo. 1997-436 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

William James Courville, Petitioner T.C. Memo. 1996-134 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency of $2,704 in petitioner's Federal income tax, and an accuracy-related penalty of $541 under 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year at issue.

Steven J. Scagliotta and Michele D. Scagliotta, Petitioners T.C. Memo. 1996-498 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year at issue.

Sheriel L. Sexcius, Petitioner T.C. Memo. 1996-175 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

Reza & Connie M. Rezazadeh, Petitioner T.C. Memo. 1996-245 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Beverly T. Rutt-Hahn, Petitioner T.C. Memo. 1996-536 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Robert W. & Patricia A. Ackerman, Petitioner T.C. Memo. 1996-315 · 1996

Dean pursuant to section 7443A(b) of the Code - 2 - 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.

Inez Meilak, Petitioner T.C. Memo. 1996-381 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Sarah R. Elgart & Stephen K. Glassman, Petitioners T.C. Memo. 1996-379 · 1996

Nameroff pursuant to section 7443A(b) and Rules - 2 - 180-182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Jack A. & Nancy Haigh, Petitioner T.C. Memo. 1996-409 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, 182.1 Respondent determined deficiencies in petitioners' 1991, 1992, and 1993 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

Gene E. & Marilyn Narramore, Petitioner T.C. Memo. 1996-11 · 1996

Pajak pursuant to section 7443A(b)(4) of the Code and Rules 180, 181, and 183.

Joel L. & Delynn E. Boyce, Petitioner T.C. Memo. 1996-439 · 1996

Nameroff pursuant to section 7443A(b)(4) and Rules - 2 - 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Anne S. & Charles G. Vick, Petitioner T.C. Memo. 1996-229 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

John K. Jorman, Jr. & Audrey Jorman, Petitioners T.C. Memo. 1996-297 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1991 Federal income tax 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

Kingman K. & Lillian L. Babcock, Petitioner T.C. Memo. 1996-89 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Arlie G. Curry, Jr., Petitioner T.C. Memo. 1996-102 · 1996

Pajak pursuant to section 7443A(b)(4) of the Code and Rules 180, 181, and 183.

Jeffery Allen Robinson, Petitioner T.C. Memo. 1996-517 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Marvin W. & Kathryn A. McPike, Petitioner T.C. Memo. 1996-46 · 1996

Nameroff pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion 1 All section references are to the Internal Revenue Code in effect for the years in issue.

Pasadena ENT Clinic, P.A., Petitioner T.C. Memo. 1996-448 · 1996

Dean pursuant to section 7443A(b)(4) - 2 - 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.

John Hodel & Louisa A. Hodel, Petitioners T.C. Memo. 1996-348 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Peter Paul Lagasse, Petitioner T.C. Memo. 1996-480 · 1996

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

John W. & Vincentia Schwartz, Petitioner T.C. Memo. 1996-88 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: These consolidated cases were assigned for hearing pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 These cases are before the Court on petitioners' motions to dismiss for lack of jurisdiction.

Shorthorn Genetic Engineering 1985-1 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1985-2 Ltd.; Walter J. Hoyt, III, TaxMatters Partner; Shorthorn Genetic Engineering 1985-3 Ltd.; Walter J. Hoyt,III, Tax Matters Partner; Shorthorn Genetic Engineering 1985-4, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1985-5 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering1982-2 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1982-4 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1982-5 Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-515 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Leo & Pauline Goldman, Petitioner T.C. Memo. 1996-274 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: These cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.

Shorthorn Genetic Engineering 1983-3 Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-515 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Thomas E. King, Petitioner T.C. Memo. 1996-52 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for taxable year 1990 in the amount of $2,481.

Imelda M. Hansen, Petitioner T.C. Memo. 1996-158 · 1996

Nameroff pursuant to section 7443A(b).1 The Court 1 All section references are to the Internal Revenue Code in effect for the year at issue.

Kent J. & Ruth W. Dawson, Petitioner T.C. Memo. 1996-45 · 1996

Goldberg pursuant to section 7443A(b)(4) 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.

Shorthorn Genetic Engineering 1983-3, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1984-2, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1983-2, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1982-1, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1984-4, Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-515 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Brent Allan Pulliam, Petitioner T.C. Memo. 1996-354 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Richard L. & Betty L. Seltzer, Petitioner T.C. Memo. 1996-240 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' 1989, 1990, and 1991 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

Richard L. & Marjorie A. Freese, Petitioner T.C. Memo. 1996-224 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for 1990 in the amount of $793.

Gerald Reginald Paulson, Petitioner T.C. Memo. 1996-560 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Keith Robert Bradbury, Petitioner T.C. Memo. 1996-182 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's 1988 and 1989 Federal income taxes in the respective amounts of $998 and $1,389.

Ben Cox, Petitioner T.C. Memo. 1996-241 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for 1990 in the amount of $2,047.

Norman Alfonzo Williams, Petitioner T.C. Memo. 1996-126 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's 1989 and 1990 Federal income taxes in the respective amounts of $1,498 and $1,536, and 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Cou

Clarence A. Hunt, Jr., Petitioner T.C. Memo. 1996-388 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Donald G. Russell, Petitioner T.C. Memo. 1996-278 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Joon H. Chong & Youngcha Kim Chong, Petitioners T.C. Memo. 1996-232 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent 1All section references are to the Internal Revenue Code in effect for the year in issue.

Charles E. King, Petitioner T.C. Memo. 1996-231 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for 1990 in the amount of $672.

Durham Farms #1 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Durham Farms #2 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Durham Farms #3 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Durham Farms #4 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Durham Farms #5 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Durham Farms #6 Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-495 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Columbia Energy Fund 1982; Regional Resources, Inc., Tax Matters Partner, f.k.a. R & R Energy, Inc., Petitioners T.C. Memo. 1996-72 · 1996

Nameroff pursuant to section 7443A(b)(4) of the Code and Rules 180, 181, and 183.1 The Court agrees with and 1 All section references are to the Internal Revenue Code in effect for the years in issue.

Frank C. Verbeck, Jr., Petitioner T.C. Memo. 1996-339 · 1996

Nameroff pursuant to section 7443A(b)(4) of the Code1 and Rules 180, 181, and 183.

Herbert F. & Lois A. Hewett, Petitioner T.C. Memo. 1996-110 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Mary Lee Sharer, Petitioner T.C. Memo. 1996-91 · 1996

Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183.

Douglas Ritter, Petitioner T.C. Memo. 1996-15 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Reza & Connie M. Rezazadeh, Petitioner T.C. Memo. 1996-245 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Poison Creek Ranches #1 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Poison Creek Ranches #2 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Poison Creek Ranches #3 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Poison Creek Ranches #4 Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-504 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Shorthorn Genetic Engineering 1982-3, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1983-1, Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-515 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Gerald L. & Joy M. Zeidler, Petitioner T.C. Memo. 1996-157 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: These consolidated cases were heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Ronald L. & Deborah L. Miller, Petitioner T.C. Memo. 1996-402 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1990 Federal income tax in the amount of $2,786.

William C. & Katherine H. White, Petitioner T.C. Memo. 1996-438 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Florin Farms #1, Ltd; Walter J. Hoyt, III, Tax Matters Partner; Florin Farms #2, Ltd; Walter J. Hoyt, III, Tax Matters Partner; Florin Farms #3, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Florin Farms #4, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Florin Farms #5, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Florin Farms #6, Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Florin Farms #7, Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-495 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

James Stewart & Mary Ann Lanphere, Petitioner T.C. Memo. 1996-40 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182.

Shorthorn Genetic Engineering 1985-1; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1985-2; Walter J. Hoyt, III, Tax Matters Partner; Shorthorn Genetic Engineering 1985-3; Walter J. Hoyt, III, TaxMatters Partner; Shorthorn Genetic Engineering 1985-4; Walter J. Hoyt,III, Tax Matters Partner; Shorthorn Genetic Engineering 1985-5; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-515 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Betty W. Thompson, Petitioner T.C. Memo. 1996-468 · 1996

Dean pursuant to section 7443A(b)(4) and Rules 180, 181 and 183.1 The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.

Bernard L. Nadeau, Jr. & Nancy L. Nadeau, Petitioners T.C. Memo. 1996-427 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' 1990, 1991, and 1992 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

John W. & Vincentia Schwartz, Petitioner T.C. Memo. 1996-88 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: These consolidated cases were assigned for hearing pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 These cases are before the Court on petitioners' motions to dismiss for lack of jurisdiction.

Lloyd Patterson, Petitioner T.C. Memo. 1996-146 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181 and 182.

Theodore W. Keller, Petitioner T.C. Memo. 1996-300 · 1996

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Henry F. Wesselman, Petitioner T.C. Memo. 1996-85 · 1996

Dean pursuant to section 7443A(b)(4) 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.

Bill R. & Carolina N. Thomas, Petitioner T.C. Memo. 1996-403 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for 1991 in the amount of $1,335.

Wayne E. & Dorothy E. Wells, Petitioner T.C. Memo. 1996-147 · 1996

MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was assigned pursuant to section 7443A(b)(4) and Rules 180 and 181.

Shorthorn Genetic Engineering 1982-1 Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-515 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Washoe Ranches #6 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Washoe Ranches #7 Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-495 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Poison Creek Ranches #1 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Poison Creek Ranches #2 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Poison Creek Ranches #3 Ltd.; Walter J. Hoyt, III, Tax Matters Partner; Poison Creek Ranches #4 Ltd.; Walter J. Hoyt, III, Tax Matters Partner, Petitioners T.C. Memo. 1996-504 · 1996

Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Bernard Michael Reed, Petitioner T.C. Memo. 1995-574 · 1995

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181 and 182.1 Respondent determined a deficiency in petitioner's 1991 Federal income tax in the amount of $1,504, and an accuracy-related penalty pursuant to section 6662(b)(1) in the amount of $300.80.

Bernard F. Kochevar, Sr. & Marlene C. Kochevar, Petitioners T.C. Memo. 1995-607 · 1995

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1990 in the amount of $6,625, and an addition to tax under section 6651(a)(1) in the amount of $494.

Steven H. Toushin, Petitioner T.C. Memo. 1995-573 · 1995

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was assigned pursuant to section 7443A(b)(4) of the Code and Rules 180, 181, and 183.1 1All Rule references are to the Tax Court Rules of Practice and Procedure.

Mark R. & Diane R. Webb, Petitioner T.C. Memo. 1995-486 · 1995

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

James E. & Cynthia R. Copley, Petitioner T.C. Memo. 1995-501 · 1995

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes for 1989 and 1990 in the respective amounts of 1 All section references are to the Internal Revenue Code in effect for the years in issue.

Spencer M. Stillman and Suzanne J. Stillman, Petitioners T.C. Memo. 1995-591 · 1995

Nameroff pursuant to section 7443A(b)2 and Rule 180-182.

William David & Judith A. Jamieson, Petitioner T.C. Memo. 1995-550 · 1995

MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Joseph D. & Mary Wilkins, Petitioner T.C. Memo. 1995-467 · 1995

Pajak pursuant to section 7443A(b)(4) of the Code and Rules 180, 181, and 183.

Robert H. Tilden, Petitioner · 2015

7443A(b)(3). 2 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and all Rule references are to the Tax Court Rules ofPractice and Procedure. - 3 - [*3] "evidence ofa timely filed petition pursuant to Reg. §301.7502-1." The parties further elaborated on their respective positions,

Douglas P. Snow, Petitioner · 2014

Pursuantto section 7443A, the ChiefJudge may assign certain types ofcases to be heard by a Special Trial Judge.

Douglas P. Snow & Deborah J. Snow, Petitioners · 2014

Pursuantto section 7443A, the ChiefJudge may assign certain types ofcases to be heard by a Special Trial Judge.

John C. Bedrosian & Judith D. Bedrosian, Petitioners · 2014

In June 2010 this case was assigned to a Special Trial Judge pursuantto section 7443A and Rules 180 and 183.

Barbara K. West, Petitioner · 2012

$ERVED MAY 2 4 2012 - 2 - MEMORANDUMFINDINGS OF FACT AND OPINION THORNTON, Judge: Pursuantto section 7443A and Rules 180 and 183, this case was assigned to and heard by ChiefSpecial Trial Judge Peter J.

Richard John Florance, Jr., Petitioner T.C. Memo. 2009-154 · 2009

Section 7443A'and Florance's Motion to Strike TCR 182, both filed June 9, 2008 he again challenged the authority of Special Trial Judges to rule in his case. In Florance's Motion for Default Judgment, filed on the same date, he made the moot argument that the IRS did not file its motion to dismiss timely .. All of Florance's motions up to this poin

Larry G. & Maria A. Walton Mitchell, Petitioner 131 T.C. No. 15 · 2008

f the application of the doctrine of res judicata, collateral estoppel, or law of the case.”14 (The quotation is from Rule 152(c); Rule 50(g) puts the list in a different order and throws 14 Rule 152 expressly governs cases where a special trial judge is “authorized to make the decision of the Court pursuant to Code section * * * 7443A(b)(2).” And section 7443A(b)(2) refers to any proceeding under section 7463--precisely the section that describes our S cases.

Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Independent Administrator, Petitioners T.C. Memo. 2006-46 · 2006

Because Special Trial Judge Couvillion was prohibited under section 7443A(c) from entering a decision in those cases, he prepared an initial report which included his proposed findings of fact and opinion (the Couvillion report) .

Omnitec Corporation, An Administratively Dissolved Corporation, Leland V. Lammert, President, Petitioners T.C. Memo. 2006-202 · 2006

nded and in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. The petition was filed pursuant to sec. 7463 as a small tax case. Prior to trial, petitioner moved to have the case considered under sec. 7443A(b)(3). Petitioner's motion was granted. In the notice of deficiency, respondent determined the addition to tax under sec. 6651(a)(2) but conceded that adjustment at trial. Counsel for respondent also advised the Court that the notice of de

Billy & Bonita M. Hyler, Petitioner T.C. Memo. 2005-26 · 2005

Armen, Jr., pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code, as amended.

Nield & Linda Montgomery, Petitioner 122 T.C. No. 1 · 2004

Panuthos, pursuant to the provisions of section 7443A(b) (4) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Ryan David Funk, Petitioner 123 T.C. No. 11 · 2004

Panuthos pursuant to the provisions of 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.

Joyce E. Beery, Petitioner 122 T.C. No. 9 · 2004

Panuthos, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 182.1 The Court 1 Section references are to the Internal Revenue Code, as amended.

Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor, Petitioners 123 T.C. No. 7 · 2004

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

Don Weber, II, Petitioner 122 T.C. No. 12 · 2004

Armen, Jr., pursuant to the provisions of section 7443A(b)(4), and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Barbara Drake, Petitioner 123 T.C. No. 20 · 2004

Panuthos, pursuant to the provisions of 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.

James G. & Linda C. Jaroff, Petitioner T.C. Memo. 2004-276 · 2004

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.

Thomas F. Noons, Petitioner T.C. Memo. 2004-243 · 2004

Armen, Jr., pursuant to the provisions of 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.

Donald J. Barnes & Beverly A. Edwards, f.k.a. Beverly A. Barnes, Petitioners T.C. Memo. 2004-266 · 2004

Goldberg pursuant to the provisions of section 7443A(b)(4), in effect at the time the petition was- filed in this SERVED NOV 2 2 2004 - 2 - case, and Rules 180, 181, and 183.¹ The Court agrees with and adopts the opinion of the Special Trial Judge, as set forth below.

Kenneth & Dorothy Hitchen, Petitioner T.C. Memo. 2004-265 · 2004

Goldberg pursuant to the provisions of section 7443A(b)(4), in effect at the time the petitions were filed in these cases, and Rules 180, 181, and 183.1 The Court agrees with 1Unless otherwise indicated, section references are to the Internal Revenue Code in effect during the years in issue, and (continued...) - 2 - and adopts the opinion of the Special Trial Judge, as set forth below.

Kenneth & Dorothy Hitchen, Petitioner T.C. Memo. 2004-265 · 2004

Goldberg pursuant to the provisions of section 7443A(b)(4), in effect at the time the petitions were filed in these cases, and Rules 180, 181, and 183.1 The Court agrees with 1Unless otherwise indicated, section references are to the Internal Revenue Code in effect during the years in issue, and (continued...) - 2 - and adopts the opinion of the Special Trial Judge, as set forth below.

John M. Mekulsia, Petitioner T.C. Memo. 2003-138 · 2003

Goldberg pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise stated, all section references are to the Internal Revenue Code in effect at the time the petition was (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth below.

The Adorno Business Company, Petitioner T.C. Memo. 2003-126 · 2003

Armen, Jr., pursuant to the provisions of 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.

Curtis B. Keene, Petitioner 121 T.C. No. 2 · 2003

R contends that - 2 - P does not have a right to audio record the hearing because it is not an “interview” within the meaning of sec.

Kathryn Bernal, Petitioner 120 T.C. No. 6 · 2003

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

Yvonne E. Thurner, Petitioner 121 T.C. No. 3 · 2003

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

James C. & Katherine Wilkins, Petitioner 120 T.C. No. 7 · 2003

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

Michael Thomas & Lori Lynn Prasil, Petitioner T.C. Memo. 2003-100 · 2003

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.

Home Health Services Trust; Robert Hogue, Trustee, Petitioners T.C. Memo. 2003-58 · 2003

Armen, Jr., pursuant to the provisions of 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.

Scott P. Thurner, Petitioner 121 T.C. No. 3 · 2003

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

Malcolm I. & Trina Lewin, Petitioner T.C. Memo. 2003-305 · 2003

Wolfe pursuant to the provisions of section 7443A(b)(4) in effect when these proceedings commenced and Rules 180, 181, and 183.

Sunshine Residential Trust; Robert Hogue, Trustee, Petitioners T.C. Memo. 2003-59 · 2003

Armen, Jr., pursuant to the provisions of 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.

The Adorno Asset Management Trust, Petitioner T.C. Memo. 2003-127 · 2003

Armen, Jr., pursuant to the provisions of 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.

Eddie Lee Williams, Petitioner T.C. Memo. 2003-216 · 2003

Dinan pursuant to the provisions of section 7443A(b)(4), in effect at the time the petition was filed in this case, and Rules 180, 181, and 183.1 The Court agrees with and 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect during the years in issue and (continued...) - 2 - adopts the opinion of the Special Trial Judge, as set forth below.

Residential Management Services Trust; Robert Hogue, Trustee, Petitioners T.C. Memo. 2003-56 · 2003

Armen, Jr., pursuant to the provisions of 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.

H. Robert Feinberg, Petitioner T.C. Memo. 2003-304 · 2003

Wolfe pursuant to the provisions of section 7443A(b)(4) in effect when these proceedings commenced and Rules 180, 181, and 183.

Lidia Lamanna, Petitioner T.C. Memo. 2003-110 · 2003

Panuthos, pursuant to the provisions of - 2 - section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

Rancho Residential Services Trust; Robert Hogue, Trustee, Petitioners T.C. Memo. 2003-57 · 2003

Armen, Jr., pursuant to the provisions of 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.

Robert S. & Margery Cohen, Petitioner T.C. Memo. 2003-303 · 2003

Wolfe pursuant to the provisions of section 7443A(b)(4) in effect when these proceedings commenced and Rules 180, 181, and 183.

Bella Vista Chiropractic Trust; Robert Hogue, Trustee, Petitioners T.C. Memo. 2003-8 · 2003

Armen, Jr., pursuant to the provisions of 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.

Richard A. Wilson, Petitioner 118 T.C. No. 33 · 2002

Armen, Jr., pursuant to the provisions of 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.

Stanley D. & Rosemary A. Clough, Petitioner 119 T.C. No. 10 · 2002

Powell pursuant to the provisions of 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.

John Maier, III, Petitioner 119 T.C. No. 16 · 2002

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

Warren L. Baker, Jr. & Dorris J. Baker, Petitioners 118 T.C. No. 28 · 2002

Panuthos pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.2 The Court 1 I wrote the Court’s majority opinion in Jackson v.

Juan El Khouri & Kitty Hunter, Petitioners T.C. Memo. 2002-170 · 2002

Armen, Jr., pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Emily T. Nichols, Petitioner T.C. Memo. 2002-269 · 2002

Panuthos pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court 1 Section references are to the Internal Revenue Code, as amended.

Franklin A. Ogden, Petitioner T.C. Memo. 2002-15 · 2002

, I will send you a determination letter providing your judicial rights." ¹(...continued) sections of the Internal Revenue Code, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure. This case was assigned pursuant to sec. 7443A(b)(4). - 3 - On April 19, 2000, the Appeals Office issued to petitioner a Notice of Determination Concerning Collection Actions Under Section 6320 and/or 6330 (notice of determination) concerning his 1984 tax liability. The determination l

Dale I. Dirkes, Petitioner T.C. Memo. 2002-60 · 2002

Dinan pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

James Edward Crawford, Petitioner T.C. Memo. 2002-10 · 2002

Panuthos pursuant to the provisions of section 7443A(b)(5) in effect when this case commenced, and Rules 180, 181, and 183.

Thomas Edward Vanstone, Petitioner T.C. Memo. 2002-133 · 2002

Dinan pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, section references are to the Internal Revenue Code as amended and Rule references are to the Tax Court Rules of Practice and Procedure.

James R. Kennedy, Petitioner 116 T.C. No. 19 · 2001

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) 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.

Robert & Laureen Coco, Petitioner T.C. Memo. 2001-80 · 2001

Panuthos pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice (continued...) - 2 - agrees with and adopts the opinion of the Special Trial Judge, which is set forth bel

David R. & Darlene Funk, Petitioner T.C. Memo. 2001-291 · 2001

Dinan pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.

Dorothy Moorhous, Petitioner 116 T.C. No. 20 · 2001

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to (continued...) - 3 - and adopts the Opinion of the Special Trial Judge, which is set forth below.

Trans World Travel, Petitioner T.C. Memo. 2001-6 · 2001

Armen, Jr., pursuant to the provisions of 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.

Nina H. Pettyjohn, Petitioner T.C. Memo. 2001-227 · 2001

Armen, Jr., pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Robert A. & M. Faye Strang, Petitioner T.C. Memo. 2001-104 · 2001

Panuthos pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Gary Gealer, Petitioner T.C. Memo. 2001-180 · 2001

Pajak pursuant to the provisions of section 7443A(b)(5) in effect when this case commenced, and Rules 180, 181, and 183.

Fennel Trust, Petitioner T.C. Memo. 2001-316 · 2001

Armen, Jr., pursuant to the provisions of 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.

Kenneth D. Hanks, Petitioner T.C. Memo. 2001-319 · 2001

Dean pursuant to the provisions of section 7443A(b)(5) as in effect when this case commenced, and Rules 180, 181, and 183.

William B. & Marjorie S. Berry, Petitioner T.C. Memo. 2001-323 · 2001

Dinan pursuant to the provisions of section 7443A(b)(5)and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.

Harold & Barbara Kupersmit, Petitioner T.C. Memo. 2001-221 · 2001

Dean pursuant to the provisions of section 7443A(b)(5) in effect when this case commenced, and Rules 180, 181, and 183.

Dale I. Dirkes, Petitioner T.C. Memo. 2001-98 · 2001

Dinan pursuant to the provisions of section 7443A(b)(5).1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Tarragon Trust, Petitioner T.C. Memo. 2001-315 · 2001

Armen, Jr., pursuant to the provisions of 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.

Kin Sang Chan, Petitioner T.C. Memo. 2001-268 · 2001

Dean pursuant to the provisions of section 7443A(b)(5), in effect when this case commenced, and Rules 180 and 181 and Interim Rule 183.

Oreland A. & Lucille S. Thornsjo, Petitioner T.C. Memo. 2001-129 · 2001

Wolfe pursuant to the provisions of section 7443A(b)(4) in effect when these proceedings commenced, 1 Cases of the following petitioners are consolidated for opinion: Donald L.

Robert A. & Nanci M. Spurgin, Petitioner T.C. Memo. 2001-290 · 2001

Armen, Jr., pursuant to the provisions of 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.

Terry Hiram Pierson, Petitioner 115 T.C. No. 39 · 2000

Armen, Jr., pursuant to the provisions of 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.

William Armstrong, Transferee, Petitioner 114 T.C. No. 5 · 2000

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Howard Goza, Petitioner 114 T.C. No. 12 · 2000

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Janet N. Moore, Petitioner 114 T.C. No. 11 · 2000

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

David R. & Darlene Funk, Petitioner T.C. Memo. 2000-169 · 2000

nd Darlene Funk, Trust, Caribe Corp., Trustee, docket No. 1371-00. - 2 - Jeremy L. McPherson, for respondent. MEMORANDUM OPINION COHEN, Chief Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5). Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special

Diane Fernandez, Petitioner 114 T.C. No. 21 · 2000

motion to strike P’s allegations of fact is denied. Francine K. Cardella, for petitioner. Rose E. Gole, for respondent. OPINION COHEN, Chief Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5). Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special

Darlene Funk, Trust, Caribe Corporation, Trustee, Petitioners T.C. Memo. 2000-169 · 2000

nd Darlene Funk, Trust, Caribe Corp., Trustee, docket No. 1371-00. - 2 - Jeremy L. McPherson, for respondent. MEMORANDUM OPINION COHEN, Chief Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5). Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special

Michael A. & Judith W. Lacher, Petitioner T.C. Memo. 2000-260 · 2000

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Crystal Beach Development of Destin Ltd.; Waters Edge Building Company, Tax Matters Partner, Petitioners T.C. Memo. 2000-170 · 2000

Armen, Jr., pursuant to the provisions of 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.

Gretchen A. Redmond, Transferee, Petitioner 114 T.C. No. 5 · 2000

Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Ronald J. & Linda Gabriel, Petitioner T.C. Memo. 2000-328 · 2000

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Daniel L. & Ingrid N. Carroll, Petitioner T.C. Memo. 2000-184 · 2000

Armen, Jr., pursuant to the provisions of section 7443A(b)(5) of the Internal Revenue Code in effect at the time of assignment and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all subsequent section (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth below.

Warren S. & Elizabeth A. West, Petitioner T.C. Memo. 2000-389 · 2000

Wolfe pursuant to the provisions of section 7443A(b)(4) in effect when these proceedings commenced, and Rules 180, 181, and 183.

Myron & Arlene Barlow, Petitioner T.C. Memo. 2000-339 · 2000

Armen, Jr., pursuant to the provisions of section 7443A(b) (5) of .the Internal Revenue Code in BERVED R0V* 3 22 - 2 - effect at the time of assignment and Rules 180, 181, and 183.¹ The Court agrees with and adopts the opinion of the Special Tri.al Judge, which is set forth below.

Myron & Arlene Barlow, Petitioner T.C. Memo. 2000-339 · 2000

Armen, Jr., pursuant to the provisions of section 7443A(b)(5) of the Internal Revenue Code in ERVED ÄQE-J2000.

Diane S. Meyer, Petitioner 115 T.C. No. 31 · 2000

Panuthos pursuant to the provisions of section 7443A(b)(4).2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Odessa Properties, Trust, Caribe Corporation, Trustee, Petitioners T.C. Memo. 2000-169 · 2000

nd Darlene Funk, Trust, Caribe Corp., Trustee, docket No. 1371-00. - 2 - Jeremy L. McPherson, for respondent. MEMORANDUM OPINION COHEN, Chief Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5). Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special

Sally-Ann Nash, Petitioner T.C. Memo. 1999-217 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Edward Turney Savage, Petitioner 112 T.C. No. 5 · 1999

Armen, Jr., pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986, as amended, and Rules 180, 181, and 182.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Vashon C. & Beverly C. Jackson, Petitioner T.C. Memo. 1999-226 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) - 2 - Respondent determined deficiencies in petitioners' Federal income taxes for 1990, 1991, and 1992 in the amounts of $6,959, $7,039, and $8,013, respectively,

Richard L. & Kathryn Dyckman, Petitioner T.C. Memo. 1999-79 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Michael B. & Lauren D. Streiff, Petitioner T.C. Memo. 1999-84 · 1999

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 183.1 Respondent determined a deficiency in petitioners' 1993 Federal income tax in the amount of $2,213.

Charles Robert Schetzer, Petitioner T.C. Memo. 1999-252 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Katherine Jean Harkless, Petitioner T.C. Memo. 1999-58 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Gerald H. Evans, Petitioner T.C. Memo. 1999-66 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

John Paul Massa, Petitioner T.C. Memo. 1999-63 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Paula M. Kelly, Petitioner T.C. Memo. 1999-140 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

George & Joan Prosman, Petitioner T.C. Memo. 1999-87 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

River City Ranches #6, J.V.; Leon Shepard, Tax Matters Partner, Petitioners T.C. Memo. 1999-209 · 1999

Goldberg, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Leon E. Richartz, Petitioner T.C. Memo. 1999-18 · 1999

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Steven D. & Judith A. Rapp, Petitioner T.C. Memo. 1999-240 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) - 2 - Respondent determined deficiencies in petitioners' Federal income taxes for 1991, 1992, and 1993 in the amounts of $2,548, $2,772, and $2,774, respectively.

Jimmy R. & Janet S. Baxter, Petitioner T.C. Memo. 1999-190 · 1999

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986, as amended and in effect at the time that the petitions were filed, and Rules 180, 181, and - 2 - 182 of the Tax Court Rules of Practice and Procedure.

Michael M. Dew, Petitioner T.C. Memo. 1999-34 · 1999

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) 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.

Tim R. Casanova & San Juanita Villareal, Petitioners T.C. Memo. 1999-28 · 1999

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) 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.

Keith R. Basham, Petitioner T.C. Memo. 1999-123 · 1999

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986, as amended, and Rules 180, 181, and 182 of the Tax Court Rules of Practice and Procedure.

James F. McGuirl, Petitioner T.C. Memo. 1999-21 · 1999

Panuthos, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Marc Eric Vidmar, Petitioner T.C. Memo. 1999-168 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Hansel Hamlin Johnson, Jr. & Janice H. Johnson, Petitioners T.C. Memo. 1999-153 · 1999

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

William N. & Beth Ann Katsaros, Petitioner T.C. Memo. 1999-23 · 1999

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1992 Federal income tax in the amount of $6,288, plus an addition to 1All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

River City Ranches #6, J.V.; Leon Shepard, Tax Matters Partner, Petitioners T.C. Memo. 1999-209 · 1999

Goldberg, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Dana L. McNaught, Petitioner T.C. Memo. 1999-25 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Curtis L. Anderson, Petitioner T.C. Memo. 1999-53 · 1999

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's 1994 and 1995 Federal income taxes in the respective amounts of $3,045 and $3,542.

Carl C. Poston, III & Sherea A. Poston, Petitioners T.C. Memo. 1999-137 · 1999

- 2 - section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: This case is before the Court on respondent's Motion for Partial Summary Judgment filed pursuant to Rule 121. As discussed in gre

Richard M. Kriske, Petitioner T.C. Memo. 1999-222 · 1999

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $2,602.

Robert L. Hawes, Petitioner T.C. Memo. 1999-152 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Leema Enterprises Incorporated, Petitioner T.C. Memo. 1999-18 · 1999

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Stanley M. & Bernice M. Ulanoff, Petitioner T.C. Memo. 1999-170 · 1999

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Clair & Judith Worthington, Petitioner T.C. Memo. 1999-113 · 1999

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Gary G. & Linda J. Hart, Petitioner T.C. Memo. 1999-236 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in (continued...) - 2 - Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1994 in the amount of $3,109.

Donald John Vitale, Petitioner T.C. Memo. 1999-272 · 1999

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $2,006.

Maria Rivera, Petitioner T.C. Memo. 1999-18 · 1999

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Samuel K. Rasco, Petitioner T.C. Memo. 1999-169 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

John A. & Margaret R. Gosling, Petitioner T.C. Memo. 1999-148 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) - 2 - Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1993 and 1994 in the amounts of $3,942 and $2,725, respectively

Dan & Elaine M. Pistoresi, Petitioner T.C. Memo. 1999-39 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.¹ ¹ Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Bernice M. & Stanley M. Ulanoff, Petitioner T.C. Memo. 1999-170 · 1999

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

William Clovis Williams, Petitioner T.C. Memo. 1999-105 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Steven Wesley Noe, Petitioner T.C. Memo. 1999-187 · 1999

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Robert J. Geiger, Petitioner T.C. Memo. 1999-59 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986, as amended and in effect at the time the petition was filed, and Rules 180, 181, and 182.

Wilbur Kenneth Griesmer, Petitioner T.C. Memo. 1999-147 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Ilya G. & Sophia K. Margolis, Petitioner T.C. Memo. 1999-24 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Walter A. & Mary Sue Barniskis, Petitioner T.C. Memo. 1999-258 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) - 2 - Respondent determined deficiencies in petitioners' Federal income taxes for 1991, 1992, and 1993 in the amounts of $2,675, $2,842, and $2,366, respectively.

Robert J. Geary, Petitioner T.C. Memo. 1999-111 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Marian Wilson, Petitioner T.C. Memo. 1999-141 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

William C. Williams, Petitioner T.C. Memo. 1999-277 · 1999

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Marian & Maria Juskuv, Petitioner T.C. Memo. 1999-144 · 1999

Goldberg, pursuant to the provisions of section 7443A(b)(4) 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.

Judith D. Lawton, Petitioner T.C. Memo. 1999-243 · 1999

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 182.

Tae M. & Young J. Kim, Petitioner T.C. Memo. 1999-261 · 1999

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) - 2 - Respondent determined deficiencies in petitioners' Federal income taxes for 1993 and 1994 in the amounts of $4,972 and $5,465, respectively, and accuracy-rel

River City Ranches #4, J.V.; Leon Shepard, Tax Matters Partner, Petitioners T.C. Memo. 1999-209 · 1999

Goldberg, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

K. Richard Keeler, Petitioner T.C. Memo. 1999-18 · 1999

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is aet forth below.

Deborah F. Robinson, Petitioner T.C. Memo. 1998-179 · 1998

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Keith K. Stroupe, Petitioner T.C. Memo. 1998-380 · 1998

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

James G. & Katherine Bourekis, Petitioner 110 T.C. No. 3 · 1998

Panuthos, pursuant to the provisions of section 7443A(b)(4).1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Randal W. Howard, Petitioner T.C. Memo. 1998-300 · 1998

Panuthos pursuant to the provisions of section 7443A(b)(4) 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.

Don & Margaret Taylor, Petitioner T.C. Memo. 1998-351 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) - 2 - Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1992 and 1994 in the amounts of $1,234 and $5,262, respectively

J. Michael Joly & Bonnie B. Joly; Jody Steven Joly; and David Andrew Joly, Petitioners T.C. Memo. 1998-361 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Ross William Bruner, Petitioner T.C. Memo. 1998-246 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

John D. & Hazel B. Smith, Petitioner T.C. Memo. 1998-212 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Pramod & Raj Tandon, Petitioner T.C. Memo. 1998-445 · 1998

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Greenberg Brothers Partnership #12, a.k.a. Lone Wolf McQuade Associates; Richard M. Greenberg, Tax Matters Partner, Petitioners 111 T.C. No. 7 · 1998

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

First Blood Associates; Wesley H. Hocker, A Partner Other Than the Tax Matters Partner, Petitioners 111 T.C. No. 7 · 1998

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Greenberg Brothers Partnership #4, a.k.a. Breathless Associates; and Richard M. Greenberg, Tax Matters Partner, Petitioners 111 T.C. No. 7 · 1998

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Fredrick J. & Ruth Wuebker, Petitioner 110 T.C. No. 31 · 1998

Goldberg, pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Gustavo & Maria Guerrero, Petitioner T.C. Memo. 1998-221 · 1998

Panuthos, pursuant to the provisions of - 2 - section 7443A(b)(4) 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.

Judith K. Guerra, a.k.a. Judith Harvey, Petitioners 110 T.C. No. 20 · 1998

Panuthos pursuant to the provisions of section 7443A(b)(3) and Rule 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Nicholas M. Romer, Petitioner T.C. Memo. 1998-238 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Hoyt and Sons Ranch Properties, Ltd., a Nevada Limited Partnership, Leroy Gilbert, Tax Matters Partner, Petitioners T.C. Memo. 1998-77 · 1998

Armen, Jr.,.pursuant to the provisions of section 7443A(b) (4) of the Internal Revenue Code of 1986, as amended, and Rt_les 180, 181, and 183.

Gregory Powell & Araminta D. Morton, Petitioners T.C. Memo. 1998-108 · 1998

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pepi Schafler, f.k.a. Pepi Summer, Petitioners T.C. Memo. 1998-86 · 1998

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code in effect during the year in issue, unless otherwise indicated.

Norman Earl Holly, Petitioner T.C. Memo. 1998-55 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code in effect for the year in issue, unless otherwise indicated.

James R. & Anita Madler, Petitioner T.C. Memo. 1998-112 · 1998

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, - 2 - 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes as follows: Year Amount 1991 $3,029 1992 676 1993 296 After concessions,2 the only issue remaining for decision is whether petitioners qualify for the $25,000 offset for rental real estate activities under section 469(i)

Alexandra M. Medlin, Petitioner T.C. Memo. 1998-378 · 1998

- 2 - MEMORANDUM OPINION DINAN, Special Trial Judge: These consolidated cases were submitted pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner Alexandra M.

Robert C. & Lucille Fors, Petitioner T.C. Memo. 1998-158 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Dwayne Worth Champ, Petitioner T.C. Memo. 1998-76 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Roger L. Williams & Geraldine Williams, Petitioners T.C. Memo. 1998-93 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1993, the taxable year in (continued...) -2- Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1993 in the amount of $2,958.

Herman E. & Sheri L. Villarroel, Petitioner T.C. Memo. 1998-247 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Emil Fankhauser, Petitioner T.C. Memo. 1998-328 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Clifford Thomas & Leah Diane Noah, Petitioner T.C. Memo. 1998-384 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

John Minor, Petitioner T.C. Memo. 1998-237 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Dai Ho & Young H. Cho, Petitioner T.C. Memo. 1998-363 · 1998

Panuthos, pursuant to the provisions of section 7443A(b)(4) 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.

Richard J. & Anna J. Sinsigalli, Petitioner T.C. Memo. 1998-425 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Richard J. & Anna J. Sinsigalli, Petitioner T.C. Memo. 1998-425 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Marko Porter, Petitioner T.C. Memo. 1998-261 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Susan L. Bay, Petitioner T.C. Memo. 1998-411 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

David R. & Margaret J. Klaassen, Petitioner T.C. Memo. 1998-241 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1994, the taxable year in (continued...) - 2 - Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1994 in the amount of $1,085.43, as well as an addition to ta

R. Lawrence Smith, III, Petitioner T.C. Memo. 1998-166 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1993 Federal income tax and an accuracy-related penalty under section 6662(a) in the respective amounts of $6,259 and $1,252.

Alice Pauline Browne, a.k.a. A. Pauline Browne, Petitioners T.C. Memo. 1998-14 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Richard Raymond Raush, Petitioner T.C. Memo. 1998-245 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Estate of Charles K. Russell, Deceased; Lavada S. Russell, Executrix; and Lavada S. Russell, Petitioners T.C. Memo. 1998-434 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.1 This case is before the Court on petitioners’ Motion for Reasonable Litigation Costs under section 7430.

Thomas H. & Donna J. Zullo Nelson, Petitioner T.C. Memo. 1998-268 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Theolia Millsap, Petitioner T.C. Memo. 1998-153 · 1998

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Kenneth & Sheila Smith, Petitioner T.C. Memo. 1998-368 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Irene E. Jones, a.k.a. Irene E. Perry-Jones, a.k.a. Irene E. Perry, Petitioners T.C. Memo. 1998-444 · 1998

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Albert William Dehr, III & Yoeng Yoep Dehr, Petitioners T.C. Memo. 1998-441 · 1998

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

James Logan Clark, Petitioner T.C. Memo. 1998-280 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was fully stipulated under Rule 122 and was submitted pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Joseph T. McQuatters, Petitioner T.C. Memo. 1998-88 · 1998

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Theodore Edward Hagadone, Petitioner T.C. Memo. 1998-352 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Jose Torres, Petitioner T.C. Memo. 1998-230 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $1,280, an addition to tax 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and

M. Maureen Polsby, Petitioner T.C. Memo. 1998-459 · 1998

Pajak pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Ronald Thomas, Petitioner T.C. Memo. 1998-438 · 1998

Panuthos pursuant to the provisions of section 7443A(b)(4) 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.

Joann Thompson, f.k.a. Joann Bates, Petitioners T.C. Memo. 1998-214 · 1998

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1994 Federal income tax and an addition to tax under section 6651(a) 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice an

Charles F. & Cheryl Sutter, Petitioner T.C. Memo. 1998-250 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Domingo Perez, Petitioner T.C. Memo. 1998-442 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code in effect for the year in issue.

Jeffrey C. & Kelly O. Stone, Petitioner T.C. Memo. 1998-437 · 1998

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

John H. & Mary E. Douglas, Petitioner T.C. Memo. 1998-165 · 1998

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in 1 All section references are to the Internal Revenue Code in effect for the years in issue, unless otherwise indicated.

Miriam Villarreal, Petitioner T.C. Memo. 1998-420 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.2 In docket No.

Donna C. Clevenger, Petitioner T.C. Memo. 1998-37 · 1998

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Charles A. & Christine J. Greene, Petitioner T.C. Memo. 1998-101 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.1 In two separate notices of deficiency respondent determined additions to petitioners' Federal income taxes for the years 1983 1All section references are to the Internal Revenue Code in effect for the taxable years in issue.

Valerie Jean Genck, Petitioner T.C. Memo. 1998-105 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

John Robert Forrest, V, Petitioner T.C. Memo. 1998-369 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in - 2 - Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax for the years as follows: Additions to Tax Year Deficiency Sec.

Robert & Diana Roberts, Petitioner T.C. Memo. 1998-301 · 1998

Panuthos, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 Unless otherwise indicated, all section references are to the Internal Revenue Code.

Lana Faye Green, Petitioner T.C. Memo. 1998-356 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Juan Villarreal, Petitioner T.C. Memo. 1998-420 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.2 In docket No.

Easy Money Associates; Richard M. Greenberg, Tax Matters Partner, Petitioners 111 T.C. No. 7 · 1998

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Travis & Jayne Sanderson, Petitioner T.C. Memo. 1998-358 · 1998

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal 1 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Barry & Debra Bulakites, Petitioner T.C. Memo. 1998-256 · 1998

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth below.

Carl W. & Barbara H. Patterson, Petitioner T.C. Memo. 1998-182 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.2 1 At the trial of this case, petitioners were represented by Robert E.

Timothy E. Butler, Petitioner T.C. Memo. 1998-355 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1993 and 1994, the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Earl L. & Nancy B. Miller, Petitioner T.C. Memo. 1998-463 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Richard L. Pickering, Petitioner T.C. Memo. 1998-142 · 1998

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction, filed November 25, 1997.

Susan E. Shores, Petitioner T.C. Memo. 1998-193 · 1998

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and 182.

Sarunas Abraitis, Petitioner T.C. Memo. 1998-239 · 1998

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Hugh Janow & Linda Janow, Petitioners T.C. Memo. 1998-94 · 1998

Pajak, pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Clarence D. Kightlinger, Petitioner T.C. Memo. 1998-357 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 * Briefs amicus curiae were filed by Robert W.

Gary James Taylor, Petitioner T.C. Memo. 1998-401 · 1998

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Stephen William Dahlgren, Petitioner T.C. Memo. 1998-32 · 1998

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Faramarz & Shelli Fayeghi, Petitioner T.C. Memo. 1998-297 · 1998

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 All section references are to the Internal Revenue Code (continued...) - 2 - agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.

Stephen Neal Swihart, Petitioner T.C. Memo. 1998-407 · 1998

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Davenport Recycling Associates; Sam Winer, Tax Matters Partner, Petitioners T.C. Memo. 1998-347 · 1998

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code in (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth below.

Robert A. & Laverne M. Hall, Petitioner T.C. Memo. 1998-336 · 1998

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1992 Federal income tax of $662.

James B. Golden, Jr. & Rayliene Golden, Petitioners T.C. Memo. 1997-355 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Robert T. Cozean, Petitioner 109 T.C. No. 10 · 1997

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

David & Shirley Singer, Petitioner T.C. Memo. 1997-325 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Victor M. Vazquez, Jr., Petitioner T.C. Memo. 1997-78 · 1997

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1992 in the amount of $818.

Thomas J. & Anne F. Gaffney, Petitioner T.C. Memo. 1997-249 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Robert Gottsegen, Petitioner T.C. Memo. 1997-314 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 1 Unless otherwise indicated, all section references are to (continued...) - 2 - The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Dennis J. & Teresa Deneault, Petitioner T.C. Memo. 1997-329 · 1997

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

George & Elam Campbell, Petitioner 108 T.C. No. 5 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, 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.

Chander & Ashima K. Kant, Petitioner T.C. Memo. 1997-217 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code as amended, unless otherwise indicated.

Deborah K. Skyrms, Petitioner T.C. Memo. 1997-69 · 1997

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Joseph S. King, Petitioner T.C. Memo. 1997-501 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter is before the Court on respondent’s Motion for Summary Judgment pursuant to Rule 121.

Robert T. Lundy, Petitioner T.C. Memo. 1997-14 · 1997

-2- section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. The issue for decision is whether pet

Hugo Madioni & Susanne J. Nicolai, Petitioner T.C. Memo. 1997-108 · 1997

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, - 2 - 181, and 182.1 Respondent determined a deficiency in petitioners' 1992 Federal income tax in the amount of $1,120.

Laurence M. Addington, Petitioner T.C. Memo. 1997-259 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Michael G. Correale, Petitioner T.C. Memo. 1997-228 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Jack Alban Koerner, Petitioner T.C. Memo. 1997-144 · 1997

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 All section references are to the Internal Revenue Code (continued...) - 2 - agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Karen Ann Keegan, Petitioner T.C. Memo. 1997-511 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, - 2 - 181, and 182.1 Respondent determined deficiencies in petitioner's Federal income taxes and accuracy-related penalties under section 6662(a) as follows: Accuracy-Related Penalty Year Deficiency Sec.

Richard A. McDowell, Petitioner T.C. Memo. 1997-500 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Eric Jennings, Petitioner T.C. Memo. 1997-433 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Manley Mullings & Melvina Barnes-Mullings, Petitioners T.C. Memo. 1997-114 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Kenneth Miles & Michon Snow Tesar, Petitioner T.C. Memo. 1997-207 · 1997

Goldberg, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Dwight D. Spann, Petitioner T.C. Memo. 1997-235 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

James E. & Kathy Walker, Petitioner T.C. Memo. 1997-76 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Janice A. Plekan, Petitioner T.C. Memo. 1997-42 · 1997

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction and petitioner's Cross Motion to 1 All section references are to the Internal Revenue Code in effect for the years in issue.

William M. Hezel, Petitioner T.C. Memo. 1997-35 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and Rule references are to the Tax Court Rules of Practice (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth

Timothy Harvey, Petitioner T.C. Memo. 1997-337 · 1997

Panuthos pursuant to the provisions of - 2 - section 7443A(b)(4) 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.

Kenneth D. Shepherd & Martha A. Gregory, Petitioners T.C. Memo. 1997-75 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Harold L. Perry, Petitioner T.C. Memo. 1997-489 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code, and Rules 180, 181, and 182,1 and is before the Court on respondent's Motion to Dismiss for Failure 1Rule references are to the Tax Court Rules of Practice and Procedure.

Robert R. & Mary B. Plante, Petitioner T.C. Memo. 1997-386 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Johnnie Everage, Petitioner T.C. Memo. 1997-373 · 1997

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Section references are to the Internal Revenue Code in effect for the year at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

George L. Willis & D. Thomas-Willis, Petitioners T.C. Memo. 1997-290 · 1997

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Stephen P. & Sharon L. Sherwood, Petitioner T.C. Memo. 1997-26 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Kenneth C. & Elaine Schmidt, Petitioner T.C. Memo. 1997-41 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Dover Corporation & Subsidiaries, Petitioner T.C. Memo. 1997-340 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Frank Shih, Jr., Petitioner T.C. Memo. 1997-181 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

David J. Wierdsma, Petitioner T.C. Memo. 1997-266 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Dean G. Steele, Petitioner T.C. Memo. 1997-307 · 1997

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code in effect for the year at issue.

Albert J. DeSantis & Helen R. DeSantis, Petitioners T.C. Memo. 1997-141 · 1997

Panuthos pursuant to the provisions of - 2 - section 7443A(b)(4) 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.

John Wadsworth, Petitioner T.C. Memo. 1997-238 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Donald N. & Rosemarie F. Merino, Petitioner T.C. Memo. 1997-385 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

E. Pauline Barnes, Petitioner T.C. Memo. 1997-25 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Linda Gibbs, Petitioner T.C. Memo. 1997-196 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

William M. Hezel, Petitioner T.C. Memo. 1997-35 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and Rule references are to the Tax Court Rules of Practice (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth

John David Zielonka, Petitioner T.C. Memo. 1997-81 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Dwight E. & Leslie E. Lee, Petitioner T.C. Memo. 1997-172 · 1997

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the tax years.

Gary A. Simko, Petitioner T.C. Memo. 1997-9 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code as amended, unless otherwise indicated.

Eli T. Sleiman, Jr. & Janie L. Sleiman, Petitioners T.C. Memo. 1997-530 · 1997

- 2 - MEMORANDUM OPINION DINAN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.2 Respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties pursuant to section 6662(a) as follows: Eli T.

Dover Corporation & Subsidiaries, Petitioner T.C. Memo. 1997-340 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Thomas H. & Maureen Hesse, Petitioner T.C. Memo. 1997-333 · 1997

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Sid L. Marquis, Petitioner T.C. Memo. 1997-179 · 1997

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's 1990 and 1991 Federal income taxes in the amounts of $3,919 and $6,376, 1All section references are to the Internal Revenue Code in effect for the taxable years in issue.

James C. & Jane A. Wetzel, Petitioner T.C. Memo. 1997-267 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

John H. Hudgens, III, Petitioner T.C. Memo. 1997-33 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Dover Corporation & Subsidiaries, Petitioner T.C. Memo. 1997-339 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Francis Z. Mischel, Petitioner T.C. Memo. 1997-350 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Pamela O'Rourke, Petitioner T.C. Memo. 1997-152 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined additions to petitioner's 1982 Federal income tax as follows: 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Paul B. & Jane C. Ding, Petitioner T.C. Memo. 1997-435 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

B. Albert & Betty M. Holowinski, Petitioner T.C. Memo. 1997-168 · 1997

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Margaret M. Merker, Petitioner T.C. Memo. 1997-277 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Josephine Chimblo and Estate of Anthony J. Chimblo, Deceased; Rosalie Monahan, Executrix, Petitioners T.C. Memo. 1997-535 · 1997

- 2 - MEMORANDUM OPINION DINAN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined additions to petitioners' Federal income taxes for the years as indicated: Catherine Chimblo and Estate of Gus Chimblo, Deceased, Catherine Chimblo, Executrix, docket No.

Richard A. Pettit, Petitioner T.C. Memo. 1997-438 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Ira S. & Robin C. Greene, Petitioner T.C. Memo. 1997-296 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt, Petitioners T.C. Memo. 1997-389 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Arnold S. & Ellen K. Jacobs, Petitioner T.C. Memo. 1997-429 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

David White, Petitioner T.C. Memo. 1997-459 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth below.

Robert Charles Fohrmeister, Petitioner T.C. Memo. 1997-159 · 1997

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code as amended, unless otherwise indicated.

Steve & Lura Pasharikoff, Petitioner T.C. Memo. 1997-208 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Steven Michael Ryan, Petitioner T.C. Memo. 1997-375 · 1997

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1990 Federal income tax and an addition to tax under section 1 Section references are to the Internal Revenue Code in effect for the year at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

Catherine Chimblo and Estate of Gus Chimblo, Deceased; Catherine Chimblo, Executrix, Petitioners T.C. Memo. 1997-535 · 1997

- 2 - MEMORANDUM OPINION DINAN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined additions to petitioners' Federal income taxes for the years as indicated: Catherine Chimblo and Estate of Gus Chimblo, Deceased, Catherine Chimblo, Executrix, docket No.

Dwight E. & Leslie E. Lee, Petitioner T.C. Memo. 1997-172 · 1997

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the tax years.

Robert D. & Patricia K. Kaliban, Petitioner T.C. Memo. 1997-271 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Joel Baker, Petitioner T.C. Memo. 1997-3 · 1997

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined 1 All section references are to the Internal Revenue Code as amended, unless otherwise indicated.

Nicholas O. Bachynsky, Petitioner T.C. Memo. 1997-138 · 1997

Pajak pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

I. C. Hemmings & Sue B. Hemmings, Petitioners T.C. Memo. 1997-121 · 1997

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

Reliable Credit Association, Inc., Petitioner T.C. Memo. 1997-68 · 1997

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Jessie J. Chambers, Petitioner · 1997

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 All section references are to the Internal Revenue Code in effect for the years in issue, unless otherwise indicated.

The Manchester Group and Subsidiaries; f.k.a. Torrey Enterprises, Inc., and Subsidiaries, f.k.a. Torrey Development Corporation and Subsidiaries, Petitioners T.C. Memo. 1997-576 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Anthony & Esther Sicari, Petitioner T.C. Memo. 1997-104 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Robert D. & Patricia K. Kaliban, Petitioner T.C. Memo. 1997-271 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Steven R. Goins, Petitioner T.C. Memo. 1997-521 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for the year 1989 in the amount of $1,849, an addition to tax in the amount of $241 pursuant to section 6651(a)(1), and an addition to tax of $58 pursuant to section 6654.

Brett W. Barnes, Petitioner T.C. Memo. 1997-516 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in - 2 - Respondent determined a deficiency in petitioner's Federal income tax for 1992 in the amount of $2,548 and an accuracy- related penalty pursuant to section 6662(a) in the am

David M. Cohn, Petitioner T.C. Memo. 1997-259 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

George P. Brown, Petitioner T.C. Memo. 1997-520 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Terry Dilozir & Kathryn A. Roditski Dilozir, Petitioners T.C. Memo. 1997-268 · 1997

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in 1 All section references are to the Internal Revenue Code in effect for the year in issue, unless otherwise indicated.

Carol Anderson, Petitioner T.C. Memo. 1997-523 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Guido Ruggiero & Kristin Ruggiero, Petitioners T.C. Memo. 1997-423 · 1997

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in the amount 1 All section references are to the Internal Revenue Code in effect for the year in issue.

David M. Cohn, Petitioner T.C. Memo. 1997-259 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Mark J. Vorwald, Petitioner T.C. Memo. 1997-15 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Daniel V. Presnick, Petitioner T.C. Memo. 1997-398 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Blair R. & Donna R. Laing, Petitioner T.C. Memo. 1997-543 · 1997

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to (continued...) - 2 - This case is before the Court on petitioners' Motion for Leave to Amend Petition, as Supplemented, filed pursuant to Rule 41.

Nemat Mostaan, Petitioner T.C. Memo. 1997-155 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Lionel & Betty Zimmer, Petitioner T.C. Memo. 1997-271 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Robert Gottsegen, Petitioner T.C. Memo. 1997-314 · 1997

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 1 Unless otherwise indicated, all section references are to (continued...) - 2 - The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Mark J. & Mary A. Fuhrman, Petitioner T.C. Memo. 1997-34 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Barbara A. Landreth, Petitioner T.C. Memo. 1997-169 · 1997

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

John & Marianne Sann, Petitioner T.C. Memo. 1997-259 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Lionel & Betty Zimmer, Petitioner T.C. Memo. 1997-271 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

David & Annette Daniel, Petitioner T.C. Memo. 1997-328 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Estate of Claude P. Brown, Deceased; Sara W. Brown, Personal Representative; and Estate of Mary Stroud Brown, Deceased, Petitioners T.C. Memo. 1997-121 · 1997

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

Laurence M. Addington, Petitioner T.C. Memo. 1997-259 · 1997

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Rilwan Adisa Salami, Petitioner T.C. Memo. 1997-347 · 1997

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Albert J. DeSantis & Helen R. DeSantis, Petitioners T.C. Memo. 1997-141 · 1997

Panuthos pursuant to the provisions of - 2 - section 7443A(b)(4) 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.

Peter D. & Carolina T. Sleiman, Petitioner T.C. Memo. 1997-530 · 1997

- 2 - MEMORANDUM OPINION DINAN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.2 Respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties pursuant to section 6662(a) as follows: Eli T.

Isaac C. Hemmings & Mary Sue Hemmings, Petitioners T.C. Memo. 1997-121 · 1997

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

Estate of Philip Meriano, Deceased; Anita Panepinto, Administratrix, Petitioners T.C. Memo. 1996-58 · 1996

Dinan pursuant to the provisions of section 7443A(b)(4) - 2 - 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.

Oliver E. Stubblefield, Petitioner T.C. Memo. 1996-537 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue, and all Rule references are to the Tax Court Rules of (continued...) For the taxable year 1991, respondent determined a deficiency in petitioner's Federal income tax

Joseph & Margaret Abraham, Petitioner T.C. Memo. 1996-479 · 1996

Carluzzo pursuant to the provisions - 2 - of section 7443A(b)(4) and Rules 180, 181 and 183.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

Beatrice Appiah, Petitioner T.C. Memo. 1996-170 · 1996

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 All section references are to the Internal Revenue Code in effect for the year in issue, unless otherwise indicated.

Pen Coal Corporation, f.k.a. P & C "Bituminous Coal", Inc., Petitioners 107 T.C. No. 14 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) 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.

Polly Paul McMahon, Petitioner T.C. Memo. 1996-523 · 1996

Panuthos, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 Section references are to the Internal Revenue Code as amended.

Kirk A. & Ida R. Crandall, Petitioner T.C. Memo. 1996-463 · 1996

MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Elaine S. Bennett, Petitioner T.C. Memo. 1996-502 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Samuel C. & Susan C. Stone, Petitioner T.C. Memo. 1996-507 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1991 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

James H. & Josephine A. Swanson, Petitioner 106 T.C. No. 3 · 1996

Held, further, Ps' failure to request an Appeals Office conference did not constitute a "[refusal] * * * to participate in an Appeals office conference" within the meaning of sec.

Alfred P. Duffy, Petitioner T.C. Memo. 1996-556 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Brenda J. Gammon, Petitioner T.C. Memo. 1996-4 · 1996

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of This case is before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be

Michael & Michelle Rough, Petitioner T.C. Memo. 1996-370 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the taxable year in issue.

Creston Swaim, Petitioner T.C. Memo. 1996-545 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1992 Federal income tax in the amount of $2,850 and additions to tax 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice

Alex Morgan Foster, Petitioner T.C. Memo. 1996-26 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue.

Thomas Glen Presley, Petitioner T.C. Memo. 1996-553 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

John D. & Karen Beatty, Petitioner 106 T.C. No. 14 · 1996

Carluzzo pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

Mario R. Sanhudo, Petitioner T.C. Memo. 1996-562 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the tax years at issue.

Vincent & Clotilde Farrell, Jr., Petitioner · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 They were tried and 1 All section references are to the Internal Revenue Code in effect for the years in issue, unless otherwise indicated.

Olin E. & Zora M. Gibson, Petitioner T.C. Memo. 1996-140 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1991 Federal income tax in the amount of $2,502.

Philip & Roberta Yarnell, Petitioner T.C. Memo. 1996-84 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Margaret Loughran Webb, Petitioner T.C. Memo. 1996-449 · 1996

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction.

Wayne Curtis McKee, Petitioner T.C. Memo. 1996-143 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and - 2 - 182.1 Respondent determined deficiencies in petitioner's Federal income tax and additions to tax as follows: ______Additions to Tax_______ Year Deficiency Sec.

James & Beverly Donehey, Petitioner T.C. Memo. 1996-376 · 1996

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Ted Cowan, Petitioner T.C. Memo. 1996-161 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1989 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in - 2 - Federal income tax in the amount of $1,249 and an addition to tax pursuant to section 6651(a) in the amount of $312.2

James M. McGaffin, III & Deborah McGaffin, Petitioners T.C. Memo. 1996-290 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1991 Federal income tax in the amount of $4,531.

Joe M. & Patricia M. Brown, Petitioner T.C. Memo. 1996-421 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Richard J. & Adele S. Montgomery, Petitioner T.C. Memo. 1996-263 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, 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.

Robert P. & Christine M. Lolli, Petitioner T.C. Memo. 1996-121 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: These consolidated cases were assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

Billie & Florence Lykins, Petitioner T.C. Memo. 1996-273 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1990 in the amount of $6,169.

Roger G. & Lilianne J. G. Maki, Petitioner T.C. Memo. 1996-209 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Ira & Helen Selvin, Petitioner T.C. Memo. 1996-398 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

David E. Jackson, Petitioner T.C. Memo. 1996-54 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1992 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in - 2 - Federal income tax in the amount of $2,238 and an accuracy- related penalty pursuant to section 6662(a) in the amount

Dudley Joseph & Myrna Dupuy Callahan, Petitioner T.C. Memo. 1996-65 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 In a notice of deficiency, respondent determined 1 All section references are to the Internal Revenue Code in effect for the years at issue, unless otherwise indicated.

Marvin F. & Patricia A. Foster, Petitioner T.C. Memo. 1996-552 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Richard E. Snyder, Petitioner T.C. Memo. 1996-342 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

James V. & Melinda S. Edmiston, Petitioner T.C. Memo. 1996-60 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 182.1 1All section references are to the Internal Revenue Code in effect for the taxable year in issue.

Joseph Francis Cunningham, Petitioner T.C. Memo. 1996-141 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code for the years in issue.

Miriam Lawrence, Petitioner T.C. Memo. 1996-479 · 1996

Carluzzo pursuant to the provisions - 2 - of section 7443A(b)(4) and Rules 180, 181 and 183.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

Alfred C. Heston, Petitioner T.C. Memo. 1996-324 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1991 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Robert D. & Anne T. Lewis, Petitioner T.C. Memo. 1996-440 · 1996

Irvin Couvillion pursuant to the provisions of section 7443A(b)(4)1 and Rules 180, 181, and 183.

Jo Ann Porter, Petitioner T.C. Memo. 1996-475 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

William & Joan Spears, Petitioner · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 They were tried and 1 All section references are to the Internal Revenue Code in effect for the years in issue, unless otherwise indicated.

Allan R. & Joan K. Powell, Petitioner T.C. Memo. 1996-264 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Milward Corporation, Petitioner T.C. Memo. 1996-391 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Ruth R. Johnson-Straub, Petitioner T.C. Memo. 1996-198 · 1996

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of This case is before the Court on respondent's Motion To Dismiss For Failure To State A Claim, as supplemented, filed

Dean W. & Lynn M. Schulze, Petitioner T.C. Memo. 1996-420 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

George W. & Margaret L. Gagnon, Petitioner T.C. Memo. 1996-430 · 1996

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 By notice of deficiency dated March 16, 1995, respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1991, 1992, and 1993 in the respective amounts 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issu

W. Robert Curtis & Cheryl L. Riess-Curtis, Petitioners T.C. Memo. 1996-371 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, and Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

On Shore Quality Control Specialist, Inc., Petitioner T.C. Memo. 1996-95 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 Respondent determined deficiencies in petitioner's Federal income taxes for the fiscal years ending August 31, 1991 and 1 All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless oth

Maria E. Reed, Petitioner · 1996

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction.

Morton & Carol David, Petitioner T.C. Memo. 1996-398 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Ernest L. & Kathleen Newsome, Petitioner T.C. Memo. 1996-522 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' 1991 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue.

Gloria A. House, Petitioner T.C. Memo. 1996-311 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1All section references are to the Internal Revenue Code in effect for the year in issue.

Steven Matthew Langley, Petitioner T.C. Memo. 1996-164 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Douglas James Crawford, Petitioner T.C. Memo. 1996-460 · 1996

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the years in issue, unless otherwise indicated.

Patricia E. Ietto, Petitioner T.C. Memo. 1996-332 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

B. Joe Rosa, Jr., An Accountancy Corporation, Petitioner T.C. Memo. 1996-322 · 1996

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 All section references are to the Internal Revenue Code in effect for the year in issue, unless otherwise indicated.

Pennel Phlander Irwin, Petitioner T.C. Memo. 1996-490 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies inpetitioner's Federal income taxes, and accuracy-related penalties as follows: 1 All section references are to the Internal Revenue Code as amended, unless otherwise indicated.

Robert Joseph & M. Patricia Looby, Petitioner T.C. Memo. 1996-207 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Leon M. & Mary K. Jaroff, Petitioner T.C. Memo. 1996-527 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

James H. Shelton, Deceased and Eve Shelton, Petitioners T.C. Memo. 1996-444 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.2 1James H.

Warren Richard Follum, Petitioner T.C. Memo. 1996-474 · 1996

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 183.1 This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction, petitioner's motion to dismiss 1 All section references are to the Internal Revenue Code in effect for the years in issue, unless otherwise indicated.

Theodore H. & Marilyn F. Black, Petitioner T.C. Memo. 1996-14 · 1996

Wolfe pursuant to the provisions of - 2 - section 7443A(b)(4) and Rules 180, 181, and 183.1 They were tried and briefed separately but consolidated for purposes of opinion.

Robert D. & Maria A. Suckley, Petitioner T.C. Memo. 1996-364 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Timothy W. & Suzanne M. Coffield, Petitioner T.C. Memo. 1996-365 · 1996

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Allan J. & Brenda Becker, Petitioner T.C. Memo. 1996-538 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Jeffrey S. Kaiser & Gail F. Kaiser, Petitioners T.C. Memo. 1996-526 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and - 2 - 182.1 Respondent determined a deficiency in petitioners' 1991 Federal income tax in the amount of $1,121.

G. Richard & Sara B. Childs, Petitioner T.C. Memo. 1996-267 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, 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.

Mark Friedman, Petitioner T.C. Memo. 1996-558 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Roger G. & Marlan W. Cotner, Petitioner T.C. Memo. 1996-428 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1All section references are to the Internal Revenue Code in effect for the year in issue.

Janet Kline, Petitioner T.C. Memo. 1996-220 · 1996

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined additions to petitioner's 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the tax year in issue, and all Rule references are to the Tax Court Rules of Practice - 2 - 1984 income tax, pursuant to section 6653(a)(1) and (2), in

Lee W. & Wendy S. Yates, Petitioner T.C. Memo. 1996-499 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181,.

Mario Kelvin Arredondo, Petitioner T.C. Memo. 1996-185 · 1996

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

David E. Morgan, Petitioner T.C. Memo. 1996-399 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Bruce & Lois Zenkel, Petitioner T.C. Memo. 1996-398 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Horace E. McCann, Petitioner T.C. Memo. 1996-120 · 1996

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 By notice of deficiency dated November 3, 1994, respondent determined a deficiency in petitioner's 1991 Federal income tax and an accuracy-related penalty pursuant to section 6662(a) in 1 Section references are to the Internal Revenue Code in effect for the year in issue.

Arthur Takamoto and Louise Takamoto, Petitioners T.C. Memo. 1996-94 · 1996

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 This case is before the Court on petitioner Louise Takamoto's (petitioner) Motion for Leave to File a Motion to 1 All section references are to the Internal Revenue Code in effect for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

Abhimanyu Swain, Petitioner T.C. Memo. 1996-22 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Angela M. Graham, Petitioner T.C. Memo. 1996-512 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Mark C. Nagy, Petitioner T.C. Memo. 1996-24 · 1996

Nameroff pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code.

Peter Pettong Chiang & Chung-Yin Chiang, Petitioners T.C. Memo. 1996-377 · 1996

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 183.1 This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction.

David & Deborah B. Alter, Petitioner T.C. Memo. 1996-558 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Fred Willie Thomas, Jr., Petitioner T.C. Memo. 1996-492 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows: 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

John & Betty Richardson Stafford, Petitioner T.C. Memo. 1996-524 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax - 2 - and adopts the opinion of the Special Trial Judge, which is set forth below.

Norma Neiman, Petitioner T.C. Memo. 1996-115 · 1996

- 2 - MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.2 Respondent determined a deficiency in the amount of $1,522 in petitioner's Federal income tax for the taxable year 1990.3 The issues for decision are: 1.

B. Theodore & Wendy Chapin, Petitioner T.C. Memo. 1996-56 · 1996

- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes in the following amounts: Year Deficiency 1987 $1,694 1988 8,337 1989 9,930 1990 9,511 1991 2,089 The issue is whether deductions related to the expenses of renting a beach condominium owned by petitioners are limited by the pas

Richard E. Snyder, Petitioner T.C. Memo. 1996-342 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Barry H. & Marilyn S. Scheiner, Petitioner T.C. Memo. 1996-554 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the tax years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Harold E. & Anna Mae Emmons, Petitioner T.C. Memo. 1996-265 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and Rules 180, 181, and 183.1 The Court agrees with and adopts the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of - 2 - Opinion of the Special Tr

Susan J. Bokhari O'Neil, Petitioner T.C. Memo. 1996-104 · 1996

Dean pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue.

Eddie M. & Cynthia L. Chandler, Petitioner T.C. Memo. 1996-51 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1989 and 1990, as well

Alonzo & Emma J. Bradley, Petitioner T.C. Memo. 1996-461 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue.

Robert G. Blount, Petitioner T.C. Memo. 1996-398 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

James Leslie Clark Valarian, Petitioner T.C. Memo. 1996-511 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1990 Federal income tax in the amount of $1,230.

Craig A. Bratcher, Petitioner T.C. Memo. 1996-252 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Harry T. Cavalaris, Petitioner T.C. Memo. 1996-308 · 1996

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Don H. Wisden, Petitioner T.C. Memo. 1996-557 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.

Frederick M. Fox, Petitioner T.C. Memo. 1996-79 · 1996

Panuthos, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 Section references are to the Internal Revenue Code as amended.

Richard G. & Anne C. Greene, Petitioner T.C. Memo. 1996-531 · 1996

MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Charles J. Dugan, Petitioner T.C. Memo. 1996-155 · 1996

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 All section references are to the Internal Revenue Code in effect for the year in issue, unless otherwise indicated.

Charles R. Roberts, Petitioner T.C. Memo. 1996-467 · 1996

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

John Bresnahan, Petitioner T.C. Memo. 1996-497 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Dean W. & Tammy R. May, Petitioner T.C. Memo. 1996-135 · 1996

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

Richard A. Stasewich, Petitioner T.C. Memo. 1996-302 · 1996

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue.

Kenneth E. Bixler, Petitioner T.C. Memo. 1996-329 · 1996

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section and chapter references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Estate of Ronald Busch, Deceased; Rochelle Busch, Executrix; and Rochelle Busch, Petitioners T.C. Memo. 1996-342 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Leon M. & Mary K. Jaroff, Petitioner T.C. Memo. 1996-527 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Tate & Lyle, Inc. and Subsidiaries, Petitioner T.C. Memo. 1996-80 · 1996

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: These cases were assigned pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 These cases are before the Court on 1 All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Marvin & Suzanne Yarnell, Petitioner T.C. Memo. 1996-84 · 1996

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Richard Bruce Begelfer, Petitioner T.C. Memo. 1995-455 · 1995

MEMORANDUM OPINION GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for 1987 in the amount of $6,538 and an addition to 1 All section references are to the Internal Revenue Code as amended and in effect for the year in issue.

Thomas N. Rawlins, Petitioner T.C. Memo. 1995-502 · 1995

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 This case was submitted at trial fully stipulated.

C. Merritt & Dorothy Pumphrey, Petitioner · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Leonard O. Scales, Petitioner T.C. Memo. 1995-544 · 1995

MEMORANDUM OPINION DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and 182.

Daryl A. Norblom, Petitioner T.C. Memo. 1995-478 · 1995

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Chan Q. & Quynh Kieu, Petitioner 105 T.C. No. 26 · 1995

Powell pursuant to the provisions of section 7443A(b)(4) 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.

Peter R. Little, Petitioner T.C. Memo. 1995-491 · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Robert R. Baker, Petitioner T.C. Memo. 1995-495 · 1995

MEMORANDUM OPINION - 2 - ARMEN, Special Trial Judge: These cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 These cases are before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted, filed pursuant to Rule 40 and section 6673(a).

Wayne & June Ellen Hairston, Petitioner T.C. Memo. 1995-566 · 1995

MEMORANDUM OPINION ARMEN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1988, 1989, and 1990, as well as an addition to tax and a penalty for

Harold L. & Gladys M. Humberson, Petitioner T.C. Memo. 1995-470 · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and Rules 180, 181, and 183.1 The Court agrees with and adopts the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Revie Cee Sorey, II, Petitioner T.C. Memo. 1995-525 · 1995

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 They were tried and briefed separately but consolidated for purposes of opinion.

Linda L. Erwin, Petitioner T.C. Memo. 1995-498 · 1995

section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE ARMEN, Special Trial Judge: Each of these cases is before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted, f

Victoria & Denis M. Lyszkowski, Petitioner T.C. Memo. 1995-602 · 1995

MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in the amount of $377 in petitioners' Federal income tax for the tax year ended 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Rolf Kirsch, Petitioner T.C. Memo. 1995-451 · 1995

MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1989 in the amount of $7,466 and 1 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Leon & Belle Atkind, Petitioner T.C. Memo. 1995-582 · 1995

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code, in effect for the year in issue, unless otherwise indicated.

Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt, Petitioners T.C. Memo. 1995-492 · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.

Duane B. & Linda L. Erwin, Petitioner T.C. Memo. 1995-498 · 1995

section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE ARMEN, Special Trial Judge: Each of these cases is before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted, f

Perry D. McBroom, Deceased and Jackie S. McBroom, Petitioners T.C. Memo. 1995-485 · 1995

MEMORANDUM OPINION GOLDBERG, Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182,1 and is before the Court on respondent's Motion for Summary Judgment and Motion to Dismiss as to Petitioner Perry D.

David C. Wilson, Petitioner T.C. Memo. 1995-525 · 1995

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 They were tried and briefed separately but consolidated for purposes of opinion.

Tashina Baker, Petitioner T.C. Memo. 1995-495 · 1995

MEMORANDUM OPINION - 2 - ARMEN, Special Trial Judge: These cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 These cases are before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted, filed pursuant to Rule 40 and section 6673(a).

James O. Henderson, Petitioner T.C. Memo. 1995-559 · 1995

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

Michael K. Jones, Petitioner T.C. Memo. 1995-472 · 1995

Powell pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.

Rob R. Olsen, Petitioner T.C. Memo. 1995-471 · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) and adopts the Opinion of the Special Trial Judge, which is set forth below.

Stanley B. & Rose M. Whitten, Petitioner T.C. Memo. 1995-508 · 1995

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to (continued...) - 2 - This case is before the Court on the parties' cross-motions for summary judgment.

Steven M. & Michele E. Grow, Petitioner T.C. Memo. 1995-594 · 1995

MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1991 in the amount of $9,957.

William Santangelo, Petitioner T.C. Memo. 1995-468 · 1995

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) This case is before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted And To Award Damages, filed pursuant

Estate of Mark R. Woodward, Deceased; Lillian H. Woodward, Executrix; and Lillian H. Woodward, Petitioners T.C. Memo. 1995-523 · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, 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.

Deborah Lynn Israel, Petitioner T.C. Memo. 1995-500 · 1995

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue.

Bruce M. Crow, Petitioner T.C. Memo. 1995-584 · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of (continued...) - 2 - and adopts the opinion of the Special Trial Judge, which is set forth bel

Rhett B. & Sandra L. Ross, Petitioner T.C. Memo. 1995-599 · 1995

Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, 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.

Paul L. & Doris J. Triemstra, Petitioner T.C. Memo. 1995-581 · 1995

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Wayne & June Ellen Hairston, Petitioner T.C. Memo. 1995-566 · 1995

MEMORANDUM OPINION ARMEN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in (continued...) Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1988, 1989, and 1990, as well as an addition to tax and a penalty for

James A. Petrie, IV, Petitioner T.C. Memo. 1995-592 · 1995

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioner's 1990 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.

Lee & Pearlene Mizell, Petitioner T.C. Memo. 1995-571 · 1995

MEMORANDUM FINDINGS OF FACT AND OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.

John S. Black, Petitioner T.C. Memo. 1995-560 · 1995

MEMORANDUM OPINION ARMEN, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Edward Lee Renfrow, Petitioner T.C. Memo. 1995-479 · 1995

MEMORANDUM OPINION DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 All section references are to the Internal Revenue Code in effect for the taxable year in issue.

Thomas B. McCarthy, Jr. & Janice R. McCarthy, Petitioners T.C. Memo. 1995-557 · 1995

MEMORANDUM FINDINGS OF FACT AND OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

Albert R. & Phyllis F. Dworkin, Petitioner T.C. Memo. 1995-533 · 1995

Wolfe pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with 1 All section references are to the Internal Revenue Code, in effect for the year in issue, unless otherwise stated.

Anthony J. & Claire L. Pace, Petitioner T.C. Memo. 1995-580 · 1995

Wolfe pursuant to the provisions of - 2 - section 7443A(b)(4) 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.

Madison Recycling Associates; David A. Beldon, Robert T. Boyd, Douglas C. Brandon, Stewart Pierce Brown, Lloyd E. Busch, David J. D'Antoni, John H.Delaney, Jr., Daniel C. Greer, Gerald O. Henderson, Charles D. Hoertz,Estate of Joseph Kessel, Thomas P. Korehle, Josiah O. Low, III, Robert J.Ripston, Howard S. Siever, Lavonne F. Siever, James W. Simpson, Jr., R.BarryUber, Lillian D. Williams, Partners Other Than The Tax Matters Partner, Petitioners T.C. Memo. 1992-605 · 1992

Wolfe pursuant to the provisions of section 7443A(b)(4) SERVED OCT 1 3 1992 and Rules 180, 181, and 183.' The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Powerstein v. Commissioner 99 T.C. 466 · 1992

Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.

Minemyer v. CIR 995 F.3d 781 · Cir.

First Western Government Securities, Inc. v. Commissioner 94 T.C. 549 · 1990

Cross v. Commissioner 98 T.C. 613 · 1992

Induni v. Commissioner 98 T.C. 618 · 1992

Bannon v. Commissioner 99 T.C. 59 · 1992

Thorne v. Commissioner 99 T.C. 67 · 1992

Moody v. Commissioner 95 T.C. 655 · 1990

Tempest Associates, Ltd. v. Commissioner 94 T.C. 794 · 1990

Roberts v. Commissioner 94 T.C. 853 · 1990

Fehlhaber v. Commissioner 94 T.C. 863 · 1990

Barbados # 7 Ltd. v. Commissioner 92 T.C. 804 · 1989

Genesis Oil & Gas, Ltd. v. Commissioner 93 T.C. 562 · 1989

Keith Scherbart v. CIR · Cir.

Keith Scherbart Janet Scherbart v. Commissioner of Internal Revenue 453 F.3d 987 · Cir.

Stanley Battat & Zmira Battat, Petitioners · 2017

Marty M. & Marilee D. Morin, Petitioner T.C. Memo. 1999-240 · 1999

Rosa Janus, Petitioner T.C. Memo. 1996-195 · 1996

O'Neill v. Commissioner 98 T.C. 227 · 1992

Aronson v. Commissioner 98 T.C. 283 · 1992

Lindsey v. Commissioner 98 T.C. 672 · 1992

Hofstetter v. Commissioner 98 T.C. 695 · 1992

1983 Western Reserve Oil & Gas Co. v. Commissioner 95 T.C. 51 · 1990

Amesbury Apartments, Ltd. v. Commissioner 95 T.C. 227 · 1990

Sente Investment Club Partnership of Utah v. Commissioner 95 T.C. 243 · 1990

Montana Sapphire Associates, Ltd. v. Commissioner 95 T.C. 477 · 1990

Polyak v. Commissioner 94 T.C. 337 · 1990

Galanis v. Commissioner 92 T.C. 34 · 1989

North Central Life Insurance v. Commissioner 92 T.C. 254 · 1989

McManus v. Commissioner 93 T.C. 79 · 1989

Bolton v. Commissioner 92 T.C. 656 · 1989

Pietanza v. Commissioner 92 T.C. 729 · 1989

Perkins v. Commissioner 92 T.C. 749 · 1989

Masek v. Commissioner 92 T.C. 814 · 1989

Welander v. Commissioner 92 T.C. 866 · 1989

Wiggins v. Commissioner 92 T.C. 869 · 1989

Hartz Mountain Industries, Inc. v. Commissioner 93 T.C. 521 · 1989

Phillips Petroleum Co. v. Commissioner 92 T.C. 885 · 1989

Ward v. Commissioner 92 T.C. 949 · 1989

Auborn v. Commissioner 93 T.C. 612 · 1989

Gold-N-Travel, Inc. v. Commissioner 93 T.C. 618 · 1989

Estate of Egger v. Commissioner 92 T.C. 1079 · 1989

Saso v. Commissioner 93 T.C. 730 · 1989

Willamette Industries, Inc. v. Commissioner 92 T.C. 1116 · 1989

Brock v. Commissioner 92 T.C. 1127 · 1989

Smith v. Commissioner 92 T.C. 1349 · 1989

Calcutt v. Commissioner 91 T.C. 14 · 1988

Terry v. Commissioner 91 T.C. 85 · 1988

Woods v. Commissioner 91 T.C. 88 · 1988

Estate of Haber v. Commissioner 91 T.C. 236 · 1988

Versteeg v. Commissioner 91 T.C. 339 · 1988

Carland, Inc. v. Commissioner 90 T.C. 505 · 1988

Bailey v. Commissioner 90 T.C. 558 · 1988

Rybak v. Commissioner 91 T.C. 524 · 1988

Clayden v. Commissioner 90 T.C. 656 · 1988

Florida Peach Corp. v. Commissioner 90 T.C. 678 · 1988

West Virginia State Medical Ass'n v. Commissioner 91 T.C. 651 · 1988

Powell v. Commissioner 91 T.C. 673 · 1988

Betz v. Commissioner 90 T.C. 816 · 1988

Loftus v. Commissioner 90 T.C. 845 · 1988

New York State Teamsters Conference Pension & Retirement Fund v. Commissioner 90 T.C. 862 · 1988

Energy Resources, Ltd. v. Commissioner 91 T.C. 913 · 1988

Bell v. Commissioner 90 T.C. 878 · 1988

Masek v. Commissioner 91 T.C. 1096 · 1988

Givens v. Commissioner 90 T.C. 1145 · 1988

Kellogg v. Commissioner 88 T.C. 167 · 1987

Loda Poultry Co. v. Commissioner 88 T.C. 816 · 1987

Patin v. Commissioner 88 T.C. 1086 · 1987

Fogg v. Commissioner 89 T.C. 310 · 1987

Rivera v. Commissioner 89 T.C. 343 · 1987

North Ridge Country Club v. Commissioner 89 T.C. 563 · 1987

Burwell v. Commissioner 89 T.C. 580 · 1987

Kallich v. Commissioner 89 T.C. 676 · 1987

Estate of Egger v. Commissioner 89 T.C. 726 · 1987

Hubbard v. Commissioner 89 T.C. 792 · 1987

Yusko v. Commissioner 89 T.C. 806 · 1987

Freytag v. Commissioner 89 T.C. 849 · 1987

Murphree v. Commissioner 87 T.C. 1309 · 1986

Michaels v. Commissioner 87 T.C. 1412 · 1986

McHan v. Commissioner 558 F.3d 326 · Cir.

United States v. Avalos · Cir.

Kanter v. Commissioner 590 F.3d 410 · Cir.

Estate Burton Kanter v. CIR · Cir.

Joshua Kanter v. CIR · Cir.

Burgess v. Federal Deposit Insurance Corp. 871 F.3d 297 · Cir.

New York Party Shuttle v. NLRB 18 F.4th 753 · Cir.

Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, and Naomi Kanter v. Commissioner of Internal Revenue 337 F.3d 833 · Cir.

§7443 — Membership

768 Citing Cases

New cases, delivered.