Docket No. 5457-79.

40 T.C.M. 508 (1980)

T.C. Memo. 1980-215

Rose C. France v. Commissioner.

United States Tax Court.

Filed June 23, 1980.

Attorney(s) appearing for the Case

William C. Dziak, for the petitioner. John R. Dorocak, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned to and heard by Special Trial Judge John J. Pajak pursuant to the provisions of section 7456(c) of the Internal Revenue Code of 1954,1 and Rules 180 and 181, Tax Court Rules of Practice and Procedure.2 The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.

Opinion of the Special...

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