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TONER v. COMMISSIONER

Docket Nos. 10826-80, 13639-80.

60 T.C.M. 1016 (1990)

T.C. Memo. 1990-539

Richard J. Toner v. Commissioner. Janice E. Toner v. Commissioner.

United States Tax Court.

Filed October 17, 1990.

Attorney(s) appearing for the Case

Richard J. Toner, pro se. Peter Goldberger, 410 Welsh St., Chester, Pa., and Pamela Wilk for petitioner Janice E. Toner. Russell K. Stewart, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

These cases were assigned to Special Trial Judge Norman H. Wolfe pursuant to the provisions of section 7443A(b) 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

WOLFE, Special Trial Judge:

In a notice of deficiency dated April 15, 1980, respondent...

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