Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
These consolidated cases were assigned to Special Trial Judge Peter J. Panuthos for the purpose of considering and ruling on respondent's Motion for Summary Judgment pursuant to Delegation Order No. 8 of this Court, 81 T.C. XXV (1983). The Court agrees with and adopts his opinion which is set forth below.
Opinion of the Special Trial Judge
PANUTHOS, Special Trial Judge:
These...
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