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FRANKLIN v. COMMISSIONER

Docket No. 9780-83.

51 T.C.M. 83 (1985)

T.C. Memo. 1985-603

Carey Allen Franklin v. Commissioner.

United States Tax Court.

Filed December 11, 1985.

Attorney(s) appearing for the Case

John Lock and Marlene K. Sparkman, for the petitioner. Sheri A. Wilcox, for the respondent.

Memorandum Opinion

STERRETT, Chief Judge:

This case was assigned to Special Trial Judge Lee M. Galloway pursuant to section 7456(c) and (d),1 General Order No. 8, 81 T.C. XXIII (1983), and Rules 180 and 181, Tax Court Rules of Practice and Procedure. The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

GALLOWAY, Special Trial Judge:

On October 31,...

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