RUSSELL NILSON, INC. v. COMMISSIONER

Docket No. 23022-88.

58 T.C.M. 1354 (1990)

T.C. Memo. 1990-61

Russell Nilson, Inc. v. Commissioner.

United States Tax Court.

Filed February 12, 1990.


Attorney(s) appearing for the Case

Catherine M. Brady, 530 Broadway, San Diego, Calif., for the petitioner. H. Steven New, for the respondent.


Memorandum Opinion

FAY, Judge:

This case was assigned to Special Trial Judge James M. Gussis pursuant to section 7443A(b)(4) of the Code 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

GUSSIS, Special Trial Judge:

This case is before the Court on respondent's Motion to Dismiss for Lack of...

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