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KUPERSMIT v. COMMISSIONER

Docket No. 3688-83.

48 T.C.M. 1017 (1984)

T.C. Memo. 1984-469

Harold P. Kupersmit and Barbara A. Kupersmit v. Commissioner.

United States Tax Court.

Filed September 4, 1984.

Attorney(s) appearing for the Case

Harold P. Kupersmit, pro se, Levittown, Pa. Eugene J. Wien, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

This case was assigned to and heard by Special Trial Judge Joan Seitz Pate pursuant to sections 7456(c) and (d) of the Internal Revenue Code of 1954, as amended, General Order No. 8 (81 T.C. XXIII) (1983), and Rules 180 and 181, Tax Court Rules of Practice and Procedure.1 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

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