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BOYER v. COMMISSIONER

Docket Nos. 6728-89, 6765-89, 6476-90, 12620-90.

64 T.C.M. 1570 (1992)

T.C. Memo. 1992-724.

Frank Boyer and the Estate of Nancy Boyer, Deceased, Frank Boyer and Edward Haberern, Co-Executors, et al. v. Commissioner.

United States Tax Court.

Filed December 22, 1992.

Attorney(s) appearing for the Case

William R. Cousins III and Lauren C. LaRue, 901 Main St., Dallas, Tex., for the petitioners. Marikay Lee-Martinez and Rachael J. Zepeda, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

These cases were assigned to Special Trial Judge D. Irvin Couvillion pursuant to the provisions of section 7443A(b)(4)2 and Rules 180, 181, and 183. The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Opinion of the Special Trial Judge

COUVILLION, Special Trial Judge:

In these consolidated cases, respondent...

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