Memorandum Findings of Fact and Opinion
DAWSON, Judge:
These consolidated cases were heard by former Special Trial Judge John H. Sacks pursuant to the provisions of section 7456(c), Internal Revenue Code of 1954. Subsequent to the trial and upon oral agreement of the parties, the cases were transferred to Judge Howard A. Dawson, Jr., by an order of the Chief Judge, for the preparation of the Findings of Fact and Opinion.
Respondent determined deficiencies...
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