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BRENNAN v. COMMISSIONER

Docket No. 4189-82.

48 T.C.M. 1165 (1984)

T.C. Memo. 1984-500

Ronald D. Brennan v. Commissioner.

United States Tax Court.

Filed September 18, 1984.

Attorney(s) appearing for the Case

Peter R. Stromer, for the petitioner. Charles W. Maurer, Jr. and Willard J. Frank, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

This case was assigned to Special Trial Judge Lee M. Galloway pursuant to the provisions of section 7456 of the Code1 and Rule 180,2 et seq. The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

GALLOWAY, Special Trial Judge:

Respondent, in his notice of...

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