Memorandum Findings of Fact and Opinion
DAWSON, Judge.
This case was heard by Chief Special Trial Judge Marvin F. Peterson pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code, and Rule 180 et seq. All section references are to the Internal Revenue Code, asamended. All Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the Chief Special Trial Judge's opinion, which is set forth...
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