Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
These cases were assigned to Special Trial Judge Randolph F. Caldwell, Jr., for trial or other disposition, pursuant to the provisions of section 7456(c) of the Internal Revenue Code of 1954, as amended, and Rule 180 of the Tax Court's Rules of Practice and Procedure. The order of assignment, dated February 12, 1981, provides that the post-trial procedures set forth in Rule 182 are not applicable. The...
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