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BAILEY v. COMMISSIONER

Docket Nos. 10193-78, 12885-80, 21771-81, 4505-82, 3781-85, 18288-85, 18721-85, 18790-85, 18966-85, 19016-85.

90 T.C. 558 (1988)

GUY B. BAILEY, JR., AND LOIS M. BAILEY, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 31, 1988.

Attorney(s) appearing for the Case

Richard A. Levine, Carlton M. Smith, and Albert Rosenblum, for the petitioners.

Gerald A. Thorpe, for the respondent.

OPINION

SCOTT, Judge:

These cases were assigned to and heard by Special Trial Judge John J. Pajak, pursuant to the provisions of section 7456 (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) of the Code and Rule 180 et seq.2 The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE...

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