Roy v. Commissioner

O. Z. AND GERTRUDE ROY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Roy v. Commissioner

Docket No. 12590-93

United States Tax Court

T.C. Memo 1995-23; 1995 Tax Ct. Memo LEXIS 22; 69 T.C.M. (CCH) 1690;

January 18, 1995, Filed

Decision will be entered for respondent with respect to the deficiency and for petitioners with respect to the addition to tax.

For petitioners: Paul D. Spillers.

For respondent: Linda A. Neal.

POWELL

POWELL

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…