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 judgment on the pleadings pursuant to 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 presently before the Court...
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