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PAYNE v. COMMISSIONER

Docket No. 23636-90.

63 T.C.M. 1778 (1992)

T.C. Memo. 1992-22

Clifford L. Payne and Jan F. Payne v. Commissioner.

United States Tax Court.

Filed January 13, 1992.

Attorney(s) appearing for the Case

Edwin B. Tatum, 921 E. 21st St., Clovis, N.M., for the petitioners. Pamelya P. Herndon, for the respondent.

Memorandum Opinion

DAWSON, Judge:

Respondent's motion to dismiss for lack of jurisdiction was assigned to Special Trial Judge D. Irvin Couvillion for hearing, consideration, and ruling thereon pursuant to 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...

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