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KELLEY v. COMMISSIONER

Docket Nos. 34982-85, 37857-86, 33957-87.

66 T.C.M. 1132 (1993)

T.C. Memo. 1993-495

Eugene and Barbara Kelley, et al., v. Commissioner.

United States Tax Court.

Filed October 27, 1993.

Attorney(s) appearing for the Case

Victor T. Fuzak and Richard F. Campbell, One M & T Plaza, Buffalo, N.Y., for the petitioners. Moira L. Sullivan, Peter J. Graziano, and James B. Biagi, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

These consolidated cases were assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge set forth below.

Opinion of the Special Trial Judge

POWELL, Special Trial Judge:

These are test cases for approximately 300 petitioners...

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