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MICHAELS v. COMMISSIONER

Docket No. 39917-85.

87 T.C. 1412 (1986)

JOHN ALBERT MICHAELS AND REBECCA HOOPER MICHAELS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 23, 1986.

Attorney(s) appearing for the Case

John Albert Michaels, pro se.

Edwina L. Charlemagne, and Deborah L. Hildebran for the respondent.

STERRETT, Chief Judge:

The parties' cross-motions for summary judgment filed herein were assigned to Special Trial Judge Joan Seitz Pate pursuant to the provisions of section 7456(d) (redesignated as sec. 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755), and Rules 180 and 181.1 After a review of the record, we agree with and adopt the opinion of the Special Trial Judge which is set forth below.

OPINION...

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