Memorandum Opinion
PETERSON, Special Trial Judge:
These cases were assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
On April 9, 1993, these cases were consolidated for trial, briefing, and opinion pursuant to Rule 141...
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