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SUMERSET PROPERTIES v. COMMISSIONER

Docket No. 5939-81.

43 T.C.M. 94 (1981)

T.C. Memo. 1981-707

Sumerset Properties v. Commissioner.

United States Tax Court.

Filed December 15, 1981.

Attorney(s) appearing for the Case

Samuel Rosenberg, for the petitioner. Joan R. Domike, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This motion was assigned to and heard by Special Trial Judge Fred S. Gilbert, Jr., pursuant to the provisions of section 7456(c) of the Internal Revenue Code.1 The Court agrees with and adopts his opinion, which is set forth below.2

Opinion of the Special Trial Judge

GILBERT, Special Trial Judge:

This case is before...

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