United States Tax Court March 17, 2000, No. 15444-99L (Goza v. Commissioner)

lead-opinion

OPINION

Cohen, Chief 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 183. Unless otherwise indicated, section references are to sections of the Internal Revenue Code as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.