T.C. Memo. 2001-8
UNITED STATES TAX COURT
PENNY J. SUTHERLAND, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15174-99. Filed January 19, 2001.
Daniel C. Ertel, for petitioner.
Robin L. Peacock, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: This case is before the Court fully stipulated.
See Rule 122. Rule references are to the Tax Court Rules of
Practice and Procedure. Unless otherwise indicated, section
references are to the Internal Revenue Code in effect for the year
in issue.
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