T.C. Memo. 2000-369
UNITED STATES TAX COURT
LARRY D. & GAIL SCOTT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3509-99. Filed December 7, 2000.
Larry D. & Gail Scott, pro sese.
Susan Smith Canavello, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Lewis R. Carluzzo pursuant to section 7443A(b)(5) 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 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect at the time that the petition was
filed in this case. Rule references are to the Tax Court Rules
of Practice and Procedure.
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