Robert Coco and Laureen Coco - Page 1

                                 T.C. Memo. 2001-80                                   

                               UNITED STATES TAX COURT                                

                    ROBERT COCO AND LAUREEN COCO, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9460-00.                     Filed April 2, 2001.           

               Ronald J. Cohen, for petitioners.                                      
               Robin L. Peacock, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               GERBER, Judge:  This case was assigned to Chief Special                
          Trial Judge Peter J. Panuthos pursuant to the provisions of                 
          section 7443A(b)(5) and Rules 180, 181, and 183.1  The Court                

               1    Unless otherwise indicated, all section references are            
          to the Internal Revenue Code in effect for the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              

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