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DURGIN v. COMMISSIONER

Docket No. 12527-90.

64 T.C.M. 1287 (1992)

T.C. Memo. 1992-656

Richard L. Durgin and Mary C. Durgin v. Commissioner

United States Tax Court.

Filed November 9, 1992.

Attorney(s) appearing for the Case

John R. Holsinger and Gerald H. Litwin, Two University Plaza, Hackensack, N.J., for the petitioners. Leslie J. Spiegel, for the respondent.

Memorandum Opinion

FAY, Judge:

This case was assigned to Special Trial Judge Carleton D. Powell 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 that is set forth below.

Opinion of the Special Trial Judge

POWELL, Special Trial Judge:

On March 19, 1990, respondent mailed a notice of deficiency to petitioner...

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