T.C. Memo. 2004-243
UNITED STATES TAX COURT
THOMAS F. NOONS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15052-02. Filed October 26, 2004.
James A. Cerks, for petitioner.
Susan M. Pinner, for respondent.
MEMORANDUM 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.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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