BAGGAO v. COMMISSIONER

JAMES J. BAGGAO AND NORMA T. BAGGAO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

BAGGAO v. COMMISSIONER

Docket No. 8154-90

United States Tax Court

T.C. Memo 1992-225; 1992 Tax Ct. Memo LEXIS 267; 63 T.C.M. (CCH) 2778;

April 16, 1992, Filed

Decision will be entered under Rule 155.

Thomas E. Crowe, for petitioners.

Fred E. Green, Jr., for respondent.

NIMS

NIMS

MEMORANDUM FINDINGS OF FACT AND OPINION

NIMS, Chief Judge: This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) of the Code. 1 The Court agrees with and adopts the Special…