OPINION
DAWSON, Chief Judge:
This case was assigned to Special Trial Judge Lehman C. Aarons (pursuant to Rule 180. et seq. of the Tax Court Rules of Practice and Procedure) to conduct the trial thereof or otherwise proceed in accordance with said Rules. This Court agrees with and adopts his opinion, set forth below, on petitioner's Motion for Summary Judgment.
OPINION OF THE SPECIAL TRIAL JUDGE
AARONS...
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