T.C. Memo. 2001-102
UNITED STATES TAX COURT
IRVIN KIRSCHENBAUM, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10133-00. Filed April 26, 2001.
Marc C. Rosenberg, for petitioner.
Jack H. Klinghoffer, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Stanley J. Goldberg, pursuant to Rules 180, 181, and 183.
Unless otherwise indicated, section references are to the
Internal Revenue Code, and Rule references are to the Tax Court
Rules of Practice and Procedure. The Court agrees with and
adopts the opinion of the Special Trial Judge, which is set forth
below.
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