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BAXTER v. COMMISSIONER

Docket No. 1251-89.

59 T.C.M. 659 (1990)

T.C. Memo. 1990-251

Albert P. and Priscilla Rae Baxter v. Commissioner.

United States Tax Court.

Filed May 23, 1990.

Attorney(s) appearing for the Case

Albert P. and Priscilla Rae Baxter, pro se. Donna Mayfield Palmer, for the respondent.

Memorandum Opinion

FAY, Judge:

This case was assigned to Special Trial Judge James M. Gussis pursuant to section 7443A(b)(4) of the Code 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

GUSSIS, Special Trial Judge:

This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction...

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