T.C. Memo. 2001-290
UNITED STATES TAX COURT
ROBERT A. AND NANCI M. SPURGIN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11196-00. Filed November 2, 2001.
Robert A. and Nanci M. Spurgin, pro sese.
Michael A. Skeen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial Judge
Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with
and adopts the opinion of the Special Trial Judge, which is set
forth below.
1 Unless otherwise indicated, 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.
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