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FLORIDA PEACH CORP. v. COMMISSIONER

Docket No. 6548-82.

90 T.C. 678 (1988)

FLORIDA PEACH CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 12, 1988.

Attorney(s) appearing for the Case

Robert Lurie (an officer), for the petitioner.

Paul Horn and Francis C. Mucciolo, for the respondent.

OPINION

FEATHERSTON, J.:

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456 of the Code.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

PANUTHOS, Special Trial Judge.

This case is before the Court on respondent's motion for summary judgment, filed pursuant...

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