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STOFFELS v. COMMISSIONER

Docket No. 9896-78.

38 T.C.M. 1154 (1979)

T.C. Memo. 1979-295

Herman Stoffels and Nell J. Stoffels v. Commissioner.

United States Tax Court.

Filed August 3, 1979.

Attorney(s) appearing for the Case

Elizabeth D. DePriest and Michael R. Morris, for respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Randolph F. Caldwell, Jr., for hearing and disposition of respondent's motion for summary judgment pursuant to the provisions of section 7456(c), Internal Revenue Code of 1954, as amended. The Court agrees with and adopts his opinion which is set forth below.

Opinion of Special Trial Judge

CALDWELL, Special Trial Judge:

This case is before the Court...

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