T.C. Memo. 2001-291
UNITED STATES TAX COURT
DAVID R. AND DARLENE FUNK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10317-00. Filed November 2, 2001.
David R. and Darlene Funk, pro sese.
Jeremy McPherson, 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. Unless otherwise
indicated, section references are to the Internal Revenue Code as
amended, and all Rule references are to the Tax Court Rules of
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