Memorandum Opinion
DAWSON, Judge:
This case was assigned to Special Trial Judge Lee M. Galloway pursuant to section 7443A(b)(4) and Rules 180, 181 and 183. All section references are to the Internal Revenue Code of 1954 as amended and in effect for the year in issue. All Rule references are to the 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...
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