T.C. Memo. 2000-220 UNITED STATES TAX COURT WILLIAM M. DONOVAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 18855-97, 23139-97. Filed July 21, 2000. Alyce C. Halchak, for petitioner. Julia A. Cannarozzi, for respondent. MEMORANDUM OPINION DAWSON, Judge: These cases were assigned to Special Trial Judge Lewis R. Carluzzo pursuant to 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. 1Unless otherwise indicated, section references are to the Internal Revenue Code in effect at the time that the petitions were filed in these cases. 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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