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RISICATO v. COMMISSIONER

Docket No. 23934-82.

48 T.C.M. 10 (1984)

T.C. Memo. 1984-238

Paul Risicato and Prudence Risicato, Deceased v. Commissioner.

United States Tax Court.

Filed May 3, 1984.

Attorney(s) appearing for the Case

Paul Risicato, Bellerose, N.Y., pro se and the deceased petitioner. Laurence Ziegler and Thaddeus Wozni, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

This case was assigned to and heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456(c),1 Internal Revenue Code of 1954, as amended, and General Order No. 8 of this Court, 81 T.C. XXIII (1983). After review of the record, we agree with and adopt his opinion which is set forth below.

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