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MARKOWSKI v. COMMISSIONER

Docket No. 30319-89.

62 T.C.M. 1525 (1991)

T.C. Memo. 1991-616

Michael J. Markowski v. Commissioner.

United States Tax Court.

Filed December 12, 1991.

Attorney(s) appearing for the Case

Max Benkel, for the petitioner. Carol Reeve, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Stanley J. Goldberg pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181 and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

GOLDBERG, Special Trial Judge:

This case is before the Court on respondent's Motion to Dismiss...

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