HERZOG v. COMMISSIONER

Docket Nos. 20378-80, 20379-80.

43 T.C.M. 807 (1982)

T.C. Memo. 1982-133

Charles W. Herzog v. Commissioner.

United States Tax Court.

Filed March 18, 1982.


Attorney(s) appearing for the Case

Charles W. Herzog, pro se., Tampa, Fla. William R. McCants, for the respondent.


Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

This motion was assigned to and heard by Special Trial Judge Fred S. Gilbert, Jr., pursuant to the provisions of section 7456(c) of the Internal Revenue Code1 and Rules 180 and 181, Tax Court Rules of Practice and Procedure.2 The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

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