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ROE v. COMMISSIONER

Docket Nos. 9918-83, 20902-83, 416-84, 2364-84, 17978-84.

52 T.C.M. 778 (1986)

T.C. Memo. 1986-510

Margaret L. Roe, et al. v. Commissioner.

United States Tax Court.

Filed October 8, 1986.

Attorney(s) appearing for the Case

O. Jan Tyler and J. Duncan Webb IV, for the petitioners. George E. Gasper, Deborah A. Butler and Rebecca W. Wolfe, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

These consolidated cases were assigned to and heard by Special Trial Judge Joan Seitz Pate pursuant to section 7456(d) and Rules 180, 181 and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Opinion of the Special Trial Judge

PATE, Special Trial Judge:

These cases involved the following deficiencies...

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