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WOLFRAM v. COMMISSIONER

Docket No. 24886-85.

54 T.C.M. 266 (1987)

T.C. Memo. 1987-422

Edward P. Wolfram, Jr. and Zula J. Wolfram v. Commissioner.

United States Tax Court.

Filed August 25, 1987.

Attorney(s) appearing for the Case

Frank J.P. McManus, 300 Bell Bldg., Toledo, Ohio, for the petitioners. Richard S. Bloom, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

This case was assigned to and heard by 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, 181 and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Opinion of the Special...

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