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.
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