BAGGAO v. COMMISSIONER

Docket No. 8154-90.

63 T.C.M. 2778 (1992)

T.C. Memo. 1992-225

James J. Baggao and Norma T. Baggao v. Commissioner.

United States Tax Court.

Filed April 16, 1992.


Attorney(s) appearing for the Case

Thomas E. Crowe, 1900 E. Flamingo Rd., Las Vegas, Nev., for the petitioners. Fred E. Green, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

NIMS, Chief Judge:

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) of the Code.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

Opinion of the Special Trial Judge

PANUTHOS, Special Trial Judge:

In her notice of deficiency dated January 25, 1990, respondent...

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