Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
This case was assigned to Special Trial Judge Hu S. Vandervort pursuant to section 7456 and Rules 180 and 181.
Opinion of the Special Trial Judge
VANDERVORT, Special Trial Judge:
This case is before the Court on petitioners' motion for summary judgment pursuant to Rule 121.
Respondent, in the Notice of Deficiency issued June 16, 1983...
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