United States Tax Court August 10, 1999, No. 733-96 (Elliott v. Commissioner)

lead-opinion

Dawson, Judge:

This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7443A(b)(3) 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.