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FUNK v. COMMISSIONER

Docket Nos. 18510-99, 1366-00, 1367-00, 1368-00, 1369-00, 1370-00, 1371-00.

79 T.C.M. 2065 (2000)

T.C. Memo. 2000-169

David R. and Darlene Funk, et al v. Commissioner.

United States Tax Court.

Filed May 23, 2000.

Attorney(s) appearing for the Case

David R. Funk and Darlene Funk, pro se in Docket No. 18510-99. Richard Marks (an officer), for the petitioners in Docket Nos. 1366-00 through 1371-00. Jeremy L. McPherson, for the respondent.

MEMORANDUM OPINION

COHEN, Chief Judge:

This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5). Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL...

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