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O'NEILL TRUST v. COMMISSIONER

Docket No. 8444-91.

98 T.C. 227 (1992)

WILLIAM J. O'NEILL, JR., IRREVOCABLE TRUST, SHELDON M. SAGER, CO-TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 2, 1992.

Attorney(s) appearing for the Case

Sheldon M. Sager and John S. Seich, for petitioner.

Katherine Lee Wambsgans, for respondent.

OPINION

NIMS, Chief Judge:

This case was assigned to Special Trial Judge James M. Gussis pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below...

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