Raccio v. Commissioner

PETER RACCIO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Raccio v. Commissioner

Docket No. 25075-82.

United States Tax Court

T.C. Memo 1984-125; 1984 Tax Ct. Memo LEXIS 545; 47 T.C.M. (CCH) 1271; T.C.M. (RIA) 84125;

March 14, 1984.

Dorothy Westover and Paul Weisman, for the respondent.

DAWSON

MEMORANDUM OPINION

DAWSON, Chief Judge: This case was assigned to Special Trial Judge Helen A. Buckley pursuant to section 7456 of the Code andRules 180 and 181 of the Tax Court's Rules of Practice and Procedure.1 The Court agrees with and adopts her opinion which is set forth below.

OPINION OF THE…