T.C. Memo. 2000-256
UNITED STATES TAX COURT
CLIFFORD E. BARBOUR, JR. AND DOROTHY D. BARBOUR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3312-97. Filed August 14, 2000.
Brian C. Quist, for petitioner Clifford E. Barbour.
Rebecca D. Harris and John R. Keenan, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to Rules 180, 181, and 183.1
1 All Rule references are to the Tax Court Rules of
Practice and Procedure. Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
taxable years in issue. However, all references to sec. 7430 are
to such section in effect when the petition was filed (Feb. 20,
1997).
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