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IMES v. COMMISSIONER

Docket No. 20112-80.

43 T.C.M. 628 (1982)

T.C. Memo. 1982-95

Bruce T. Imes and Miriam L. Imes v. Commissioner.

United States Tax Court.

Filed February 23, 1982.

Attorney(s) appearing for the Case

Bruce T. Imes and Miriam L. Imes, pro se, Russell, N.Y. Frances J. Elward, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Darrell D. Hallett, for hearing on January 6, 1982, at the Motions Session of the Court in Washington, D.C., on respondent's motion for summary judgment. After a review of the record, we agree with and adopt the Special Trial Judge's opinion which is set forth below.

Opinion of the Special Trial Judge

HALLETT, Special Trial Judge:

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