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MURPHREE v. COMMISSIONER

Docket No. 1000-85.

87 T.C. 1309 (1986)

TERENCE H. MURPHREE AND MARY V. MURPHREE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 8, 1986.

Attorney(s) appearing for the Case

James V. Looby, for the petitioners.

Joseph T. Chalhoub, for the respondent.

OPINION

STERRETT, Chief Judge:

This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7456(d) (redesignated as section 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2754) and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

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