ELLIOTT v. COMMISSIONER

Docket No. 733-96.

113 T.C. 125 (1999)

HERBERT C. ELLIOTT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 10, 1999.


Attorney(s) appearing for the Case

John H. Trader, for petitioner.

Dennis R. Onnen, for respondent.


DAWSON, Judge:

This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

POWELL, Special Trial Judge:

Respondent determined a deficiency in petitioner's 1990 Federal income tax in...

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