Farley

JAMES A. FARLEY AND SHARON L. FARLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Farley

Docket No. 2366-84

United States Tax Court

T.C. Memo 1993-31; 1993 Tax Ct. Memo LEXIS 31; 65 T.C.M. (CCH) 1807;

January 27, 1993, Filed

Decision will be entered for respondent.

For petitioners: Kevin O'Connell.

For respondent: Kathey I. Shaw.

GOLDBERG

GOLDBERG

MEMORANDUM OPINION

GOLDBERG, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are…