LOSMANN v. COMMISSIONER

Docket No. 9420-86.

59 T.C.M. 172 (1990)

T.C. Memo. 1990-149

Jacque F. Losmann v. Commissioner.

United States Tax Court.

Filed March 20, 1990.


Attorney(s) appearing for the Case

Robert A. Housman, (specially recognized) for the petitioner. Robert S. Scarbrough, for the respondent.


Memorandum Opinion

SCOTT, Judge:

This case was assigned to Special Trial Judge Lee M. Galloway pursuant to section 7443A(b)(4) of the Internal Revenue Code of 1986 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

GALLOWAY, Special Trial Judge:

Respondent determined the following deficiency in and...

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