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FUNK v. COMMISSIONER

Docket No. 10317-00.

82 T.C.M. 847 (2001)

T.C. Memo. 2001-291

David R. and Darlene Funk v. Commissioner.

United States Tax Court.

Filed November 2, 2001.

Attorney(s) appearing for the Case

David R. and Darlene Funk, pro sese. Jeremy McPherson, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Daniel J. Dinan pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183. 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...

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