Memorandum Opinion
DRENNEN, Judge:
This case was assigned to and heard by Special Trial Judge Joan Seitz Pate pursuant to section 7456, Internal Revenue Code of 1954, as amended, Rules 180 and 181 of the Tax Court's Rules of Practice and Procedure, and General Order No. 8 of this Court, 81 T.C. XXIII (1983).
Opinion of the Special Trial Judge
PATE, Special Trial Judge:
Respondent determined deficiencies...
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