T.C. Memo. 2000-299
UNITED STATES TAX COURT
ROBERT LLOYD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1477-97, 6774-97. Filed September 25, 2000.
Irvin W. Fegley, for petitioner.
Margaret S. Rigg, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: These cases were assigned to Special Trial
Judge Norman H. Wolfe pursuant to the provisions of Rules 180,
181, and 183. All section references are to the Internal Revenue
Code in effect at the time the petition was filed, unless
otherwise indicated. All Rule references are to the Tax Court
Rules of Practice and Procedure. The Court agrees with and
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