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SMITH v. COMMISSIONER

Docket Nos. 17336-79 and 17337-79.

40 T.C.M. 1315 (1980)

T.C. Memo. 1980-410

Hugh L. Smith and Lois J. Smith v. Commissioner.

United States Tax Court.

Filed September 22, 1980.

Attorney(s) appearing for the Case

Larry N. Johnson and Ruth E. Salek, for respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

These cases were assigned to Special Trial Judge Randolph F. Caldwell, Jr., for hearing and disposition of respondent's motions for judgment on the pleadings. The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

Opinion of the Special Trial Judge

CALDWELL, Special Trial Judge:

These cases are before the Court on respondent's motion in...

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