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  5. 64 T.C.M. 546 (1992)
 

ACKERS III v. COMMISSIONER

Docket Nos. 6717-77, 6729-77, 6734-78, 6759-78, 5874-80, 5875-80, 5876-80.

64 T.C.M. 546 (1992)

T.C. Memo. 1992-476.

J. Clark Akers III and Eleanor M. Akers, et al. v. Commissioner.

United States Tax Court.

Filed August 20, 1992.

Attorney(s) appearing for the Case

Mark H. Westlake, 424 Church St., Nashville, Tenn., for the petitioners. Vallie C. Brooks and Robert B. Nadler, for the respondent.

Supplemental Memorandum Opinion

DAWSON, Judge:

After remand by the United States Court of Appeals for the Sixth Circuit, these cases were reassigned to Special Trial Judge Lee M. Galloway pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Opinion of the Special Trial Judge

GALLOWAY,...

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