Memorandum Opinion
DAWSON, Chief Judge:
This case was assigned pursuant to Delegation Order No. 8, 81 T.C. VII (1983) to Special Trial Judge John J. Pajak for the purpose of considering and ruling on respondent's Motion for Summary Judgment. After reviewing the record, we agree with and adopt his opinion which is set forth below.
Opinion of the Special Trial Judge
PAJAK, Special Trial Judge:
This case is before the Court on respondent...
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