T.C. Memo. 2001-180
UNITED STATES TAX COURT
GARY GEALER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8232-99. Filed July 20, 2001.
Lon B. Isaacson, for petitioner.
Irene Scott Carroll and Gary M. Slavett, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge John J. Pajak pursuant to the provisions of section
7443A(b)(5) in effect when this case commenced, and Rules 180,
181, and 183. All section references are to the Internal Revenue
Code, as amended, and all Rule references are to the Tax Court
Rules of Practice and Procedure. The Court agrees with and
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