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PORTILLO v. COMMISSIONER

Docket No. 6011-68.

58 T.C.M. 1386 (1990)

T.C. Memo. 1990-68

Ramon Portillo and Dolores Portillo v. Commissioner.

United States Tax Court.

Filed February 13, 1990.

Attorney(s) appearing for the Case

David P. Leeper, 661 Mesa Hills, El Paso, Tex., for the petitioners. William R. Leighton and Lewis J. Hubbard, Jr., for the respondent.

Memorandum Opinion

FAY, Judge:

This case was assigned to Special Trial Judge James M. Gussis pursuant to section 7443A(b) 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:

Respondent determined a deficiency in petitioners' Federal income tax for the year 1984...

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