T.C. Memo. 2001-6 UNITED STATES TAX COURT TRANS WORLD TRAVEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12390-96. Filed January 17, 2001. Steven S. Brown and Daniel T. Hartnett, for petitioner. Patricia Pierce Davis, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, 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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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