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SEYKOTA v. COMMISSIONER

Docket Nos. 14936-82, 47868-86, 6720-87, 31972-87.

61 T.C.M. 2706 (1991)

T.C. Memo. 1991-234

Edward A. Seykota, et al. v. Commissioner.

United States Tax Court.

Filed May 28, 1991.

Attorney(s) appearing for the Case

Stuart E. Siegel,2, * Matthew D. Lerner, Marie T. Reilly and William M. Wiltshire, 839 17th St., N.W., Washington, D.C., and F. Whitten Peters, for the petitioners. Robert McDonough, 1000 Connecticut Ave., N.W., Washington, D.C., and Richard Hindlian, for the petitioner in Docket No. 14936-82.3 Theodore L. Craft, for the petitioners in Docket No. 6720-87. William C. Sabin, Jr., Marsha Keyes, Kathleen E. Whatley, and C. Ted Sanderson, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 183.4 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

PANUTHOS, Special Trial Judge:

By timely notices of deficiencies...

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