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MILETI v. COMMISSIONER

Docket No. 21589-89.

60 T.C.M. 252 (1990)

T.C. Memo. 1990-383

Nick J. Mileti and Gretchen Mileti v. Commissioner.

United States Tax Court.

Filed July 24, 1990.

Attorney(s) appearing for the Case

Theodore M. Garver, 1101 Euclid Ave., Cleveland, Ohio, and Alan Gordon Lipson, Keith Bldg., Cleveland, Ohio, for the petitioners. J. Scott Broome, for the respondent.

Memorandum Opinion

FAY, Judge:

This case was assigned to Special Trial Judge Joan Seitz Pate pursuant to the provisions of section 7443A(b) and Rule 180, et seq.1 After a review of the record, we agree with and adopt her opinion which is set forth below.

Opinion of the Special Trial Judge

PATE, Special Trial Judge:

Respondent determined a deficiency in petitioners' 1977 Federal income tax of $98,338...

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