T.C. Memo. 2001-80
UNITED STATES TAX COURT
ROBERT COCO AND LAUREEN COCO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9460-00. Filed April 2, 2001.
Ronald J. Cohen, for petitioners.
Robin L. Peacock, for respondent.
MEMORANDUM OPINION
GERBER, Judge: This case was assigned to Chief Special
Trial Judge Peter J. 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
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