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DAVIS v. COMMISSIONER

Docket No. 3176-89.

60 T.C.M. 666 (1990)

T.C. Memo. 1990-473

Joel D. Davis and Evelyn Davis v. Commissioner.

United States Tax Court.

Filed August 30, 1990.

Attorney(s) appearing for the Case

Helen E. Marmoll, 3097 James Madison Hwy., Haymarket, Va., for the petitioners. Warren P. Simonsen, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

This case was assigned to Special Trial Judge Stanley J. Goldberg pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 19861 and Rule 180 et seq., Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

GOLDBERG...

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