Memorandum Findings of Fact and Opinion
DAWSON, Judge:
This motion for summary judgment was assigned to and heard by Commissioner Randolph F. Caldwell, Jr. The Court agrees with and adopts his opinion which is set forth below.
Opinion of the Commissioner
This case is presently before the Court on respondent's motion for summary judgment filed on July 18, 1974, pursuant to Rule 121, Tax Court's Rules of Practice...
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