TONY v. COMMISSIONER

Docket No. 39921-85X.

63 T.C.M. 2422 (1992)

T.C. Memo. 1992-155

Tony and Susan Alamo Foundation v. Commissioner.

United States Tax Court.

Filed March 18, 1992.


Attorney(s) appearing for the Case

Kenneth R. Mourton and Neal Ross Pendergraft, for the petitioner. Michael W. Bentley and Daniel C. Brauweiler, for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Larry L. Nameroff 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 Trial Judge

NAMEROFF, Special Trial Judge:

In 1984, after examining the records and activities of the...

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