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WHITTAKER v. COMMISSIONER

Docket No. 15802-86.

63 T.C.M. 1811 (1992)

T.C. Memo. 1992-29

John G. and Cecilia B. Whittaker v. Commissioner.

United States Tax Court.

Filed January 14, 1992.

Attorney(s) appearing for the Case

Loren W. Hershey, for the petitioners. Patricia A. Donahue and Stephen Ianello, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.

Opinion of the Special Trial Judge

COUVILLION, Special Trial Judge:

Respondent determined deficiencies in and additions to petitioners...

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