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SMITH v. COMMISSIONER

Docket Nos. 10171-86, 10172-86.

92 T.C. 1349 (1989)

KEVIN SMITH AND AMY SMITH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT HOWARD BENATOVICH AND LANA BENATOVICH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 28, 1989.

Attorney(s) appearing for the Case

Victor T. Fuzak, for the petitioners.

Robert W. Sadowski and Laurence A. Hoch, for the respondent.

OPINION

PARKER, Judge:

These cases were assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 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

POWELL, Special Trial Judge...

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