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HUFF v. COMMISSIONER

Docket No. 12942-09.

135 T.C. 605 (2010)

GEORGE C. HUFF, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 22, 2010.

Attorney(s) appearing for the Case

William M. Sharp, Lawrence R. Kemm, Joseph A. DiRuzzo, III, and Marjorie Rawls Roberts, for petitioner.

Daniel N. Price, Ladd Christman Brown, Jr., and Justin L. Campolieta, for respondent.

OPINION

JACOBS, Judge:

This matter is before the Court on petitioner's motion to interplead the Government of the U.S. Virgin Islands (Virgin Islands) in this proceeding. For the reasons set forth infra, we shall deny petitioner's motion.

Background

I. Procedural Background

The basic facts in this case are set forth in Huff v. Commissioner, 135 T.C. 222 (2010...

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