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PERSSON v. COMMISSIONER

Docket Nos. 6472-86, 41889-86.

58 T.C.M. 409 (1989)

T.C. Memo. 1989-567

Bruce G. Persson and Elizabeth M. Persson v. Commissioner. James D. Wood v. Commissioner.

United States Tax Court.

Filed October 19, 1989.

Attorney(s) appearing for the Case

Leslie M. Apple and Richard E. Hoben, 126 State St., Albany, N.Y., for the petitioners. Robert E. Marum and Nancy M. Vinocur, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

These consolidated cases1 were assigned to Special Trial Judge D. Irvin Couvillion pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rule 180 et seq.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

COUVILLION...

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