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  5. 66 T.C.M. 23 (1993)
 

SUIVSKI v. COMMISSIONER

Docket No. 22495-89.

66 T.C.M. 23 (1993)

T.C. Memo. 1993-291

Charles and Nereyda C. Suivski v. Commissioner.

United States Tax Court.

Filed July 7, 1993.

Attorney(s) appearing for the Case

Jorge Rodriquez-Chomat, 825 S. Bayshore Dr., Miami, Fla., for the petitioners. Linda J. Wise, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Opinion of the Special Trial Judge

COUVILLION, Special Trial Judge:

This case is part of a national litigation project which...

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