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HAALAND v. COMMISSIONER

Docket No. 6267-82.

48 T.C.M. 378 (1984)

T.C. Memo. 1984-335

David A. Haaland and Joanne Haaland v. Commissioner.

United States Tax Court.

Filed June 27, 1984.

Attorney(s) appearing for the Case

Sebastian D'Amico, 3838 Camino del Rio North, San Diego, Calif., for the petitioners. William H. Quealy, Jr., Joseph T. Chalhoub and Thomas M. Cryan, for the respondent.

Memorandum Opinion

DAWSON, Chief Judge:

Respondent's Motion for Reconsideration and Revision of Order was assigned to Special Trial Judge Francis J. Cantrel for hearing, consideration and ruling thereon. After a review of the record, we agree with and adopt his opinion which is set forth below.

Opinion of the Special Trial Judge

CANTREL, Special Trial Judge:

This case is before the...

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