T.C. Memo. 2001-98
UNITED STATES TAX COURT
DALE I. DIRKES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11924-98. Filed April 24, 2001.
Dale I. Dirkes, pro se.
Frederick W. Krieg, 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).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 for the year in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
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