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EST, AN EDUCATIONAL CORPORATION v. COMMISSIONER

Docket Nos. 8043-80, 8998-81.

52 T.C.M. 920 (1986)

T.C. Memo. 1986-527

est, An Educational Corporation v. Commissioner.

United States Tax Court.

Filed October 23, 1986.

Attorney(s) appearing for the Case

Alan B. Hoffman and W. Bruce Springer, for the petitioner. Stephen M. Miller, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

These consolidated cases were assigned for trial or other disposition to Special Trial Judge James M. Gussis pursuant to section 7456(d) 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

GUSSIS, Special Trial Judge:

Respondent determined...

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