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RHODES v. COMMISSIONER

Docket Nos. 32852-85, 23567-88.

68 T.C.M. 79 (1994)

T.C. Memo. 1994-321

Arthur W. and Ann R. Nash Rhodes v. Commissioner. Arthur W. Rhodes v. Commissioner.

United States Tax Court.

Filed July 14, 1994.

Attorney(s) appearing for the Case

Ross Alan Rhodes, for the petitioners in Docket Nos. 32852-85 and 23567-88. John A. Garraty, Jr., 101 Park Ave., New York, N.Y., for the petitioners in Docket No. 32852-85. Pamela S. Wilson and Rajiv Madan, for the respondent.

Memorandum Findings Of Fact And Opinion

DAWSON, Judge:

These consolidated cases were assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181 and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge which is set forth below.

Opinion Of The Chief Special Trial Judge

PANUTHOS, Chief Special Trial Judge:

Respondent...

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