Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
This case was assigned to and heard by Special Trial Judge Fred R. Tansill pursuant to the provisions of General Order No. 6 of this Court, 69 T.C. XV (1978). The Court agrees with and adopts his opinion which is set forth below.
Opinion of the Special Trial Judge
TANSILL, Special Trial Judge:
Respondent determined a deficiency in petitioners' Federal income tax for 1978 in...
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