Memorandum Findings of Fact and Opinion
STERRETT, Judge:
This case was assigned to and heard by Special Trial Judge Randolph F. Caldwell, Jr., pursuant to the provisions of section 7456(c), I.R.C. 1954, and Rules 180, 181 of the Tax Court Rules of Practice and Procedure. Respondent filed an exception to the Special Trial Judge's report, pursuant to Rule 182(c), Tax Court Rules of Practice and Procedure, on August 28, 1978. The Court agrees with and adopts...
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