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MONTGOMERY v. COMMISSIONER

Docket No. 16864-02L.

122 T.C. 1 (2004)

122 T.C. No. 1

NIELD AND LINDA MONTGOMERY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 22, 2004.

Attorney(s) appearing for the Case

Duncan C. Turner and Brian G. Isaacson, for petitioners.

Glenn P. Thomas and Julie L. Payne, for respondent.

OPINION

DAWSON, Judge:

This case was assigned to Chief Special Trial Judge Peter J. Panuthos, pursuant to the provisions of section 7443A(b)(4) 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

PANUTHOS, Chief Special Trial Judge:

This...

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