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CHARLTON v. COMMISSIONER

Docket Nos. 46689-86, 19295-87, 19297-87, 21098-87.

60 T.C.M. 324 (1990)

T.C. Memo. 1990-402

Thomas E. and Judith C. Charlton, et al. v. Commissioner.

United States Tax Court.

Filed July 31, 1990.

Attorney(s) appearing for the Case

Larry Kars, 250 W. 57th St., New York, N.Y., for the petitioners. Doreen M. Susi and Robert Cuatto,* for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Pate pursuant to the provisions of section 7443A(b) and Rules 180 and 181.2 The Court agrees with and adopts her opinion which is set forth below.

Opinion of the Special Trial Judge

PATE, Special Trial Judge:

This proceeding concerns respondent's determination of deficiencies in tax and additions to tax...

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