United States Tax Court December 23, 1986, Docket No. 39917-85 (Michaels v. Commissioner)

lead-opinion

STERRETT, Chief Judge:

The parties’ cross-motions for summary judgment filed herein were assigned to Special Trial Judge Joan Seitz Pate pursuant to the provisions of section 7456(d) (redesignated as sec. 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755), and Rules 180 and 181.