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BARBADOS # 7 LTD. v. COMMISSIONER

Docket Nos. 31399-87, 31400-87, 31401-87.

92 T.C. 804 (1989)

BARBADOS # 7 LTD., BAJAN SERVICES, INC., TAX MATTERS PARTNER, ET AL., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 17, 1989.

Attorney(s) appearing for the Case

Stanley Hagendorf, for the petitioner.

William A. Heard III, and R. Alan Lockyear, for the respondent.

OPINION

SCOTT, Judge:

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.2 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:

These cases came before the Court on petitioner's motions for summary judgment and petitioner...

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