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FUNK v. COMMISSIONER

Docket No. 6743-04.

123 T.C. 213 (2004)

123 T.C. No. 11

RYAN DAVID FUNK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 18, 2004.

Attorney(s) appearing for the Case

Ryan David Funk, pro se.

David A. Abernathy, Peter K. Reilly, and Jeremy L. McPherson, 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)(5) and Rules 180, 181, and 183.1 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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