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SWOPE v. COMMISSIONER

Docket No. 15633-90.

64 T.C.M. 716 (1992)

T.C. Memo. 1992-536

Layne Sampson Swope v. Commissioner.

United States Tax Court.

Filed September 14, 1992.

Attorney(s) appearing for the Case

Kenneth P. Fehl, 736 E. Meadow Dr., Palto Alto, Calif., for the petitioner. William D. Reese, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. The Court filed its Memorandum Opinion, Swope v. Commissioner [Dec. 48,253(M)], T.C. Memo. 1992-309, on June 1, 1992. All section references are to the Internal Revenue Code. All Rule references are to the Tax Court Rules of Practice and Procedure.

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