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DOVIDIO v. COMMISSIONER

Docket No. 15437-90.

61 T.C.M. 2606 (1990)

T.C. Memo. 1991-211

Thomas P. and Janet S. Dovidio v. Commissioner.

United States Tax Court.

Filed May 15, 1990.

Attorney(s) appearing for the Case

Thomas P. Dovidio, pro se. Mary Schewatz, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Larry L. Nameroff pursuant to section 7443A(b) of the Code1 and Rule 180 et seq. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

NAMEROFF, Special Trial Judge:

In a notice of deficiency dated April 3, 1990, respondent determined deficiencies...

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