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McMANUS v. COMMISSIONER

Docket No. 31784-84R.

93 T.C. 79 (1989)

CHARLES E. McMANUS, III (A PROFESSIONAL LAW CORPORATION), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 24, 1989.

Attorney(s) appearing for the Case

Charles E. McManus, III, pro se.

Sarah A. Hall, for the respondent.

SCOTT, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel pursuant to the provisions of section 7443A(b)(1) and Rule 180 et seq.1 After a review of the record, we agree with and adopt his opinion which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

CANTREL, Special Trial Judge:

By his motion, which we herein decide, respondent requests the Court to dismiss this declaratory...

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