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SIMONELLI v. COMMISSIONER

Docket Nos. 8210-78, 30883-81.

49 T.C.M. 469 (1985)

T.C. Memo. 1985-12

Salvatore Simonelli v. Commissioner.

United States Tax Court.

Filed January 9, 1985.

Attorney(s) appearing for the Case

Allen B. Pearl, Three ADP Boulevard, Roseland, N. J., for the petitioner. Caroline R. Ades and Matthew Magnone, 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, 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.

Opinion of the Special Trial Judge

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