T.C. Memo. 1998-438 UNITED STATES TAX COURT RONALD THOMAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3595-98. Filed December 15, 1998. Joseph L. Gibson, Jr., for petitioner. Stuart Spielman and Helen F. Rogers, for respondent. MEMORANDUM OPINION DAWSON, Judge: This case was assigned to Chief Special Trial Judge Peter J. 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. 1 All section references are to the Internal Revenue Code as amended. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 Next
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