T.C. Memo. 2001-323
UNITED STATES TAX COURT
WILLIAM B. BERRY AND MARJORIE S. BERRY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6786-00. Filed December 28, 2001.
Marcia Allen Broughton, for petitioners.
Julia L. Wahl, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Daniel J. Dinan pursuant to the provisions of section
7443A(b)(5)and Rules 180, 181, and 183.1 The Court agrees with
1 Unless otherwise indicated, section references are to the
Internal Revenue Code as amended, and Rule references are to the
Tax Court Rules of Practice and Procedure.
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