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JOHNSON v. COMMISSIONER

Docket No. 12027-77.

46 T.C.M. 254 (1983)

T.C. Memo. 1983-298

Marvin A. and Barbara A. Johnson v. Commissioner.

United States Tax Court.

Filed May 25, 1983.

Attorney(s) appearing for the Case

Alan R. Harter, 530 S. 4th St., Las Vegas, Nev., for the petitioners. Ronald D. Dalrymple and Robert T. Hollohan for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent's Motion for Summary Judgment filed herein. After a review of the record, we agree with and adopt his opinion which is set forth below.1

Opinion of the Special Trial Judge

CANTREL...

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