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ZIEGLER v. COMMISSIONER

Docket Nos. 977-83, 1032-83.

49 T.C.M. 182 (1984)

T.C. Memo. 1984-620

Ronald Ziegler and Leona Ziegler v. Commissioner. Harry Schwartz and Irene Schwartz v. Commissioner.

United States Tax Court.

Filed November 28, 1984.

Attorney(s) appearing for the Case

Ronald Ziegler, Huntingdon Valley, Pa., and Harry Schwartz, Philadelphia, Pa. pro se. David M. Kuchinos, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

This case was assigned to and heard by Special Trial Judge Joan Seitz Pate pursuant to section 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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