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CHAKALES v. COMMISSIONER

Docket No. 12155-84.

68 T.C.M. 479 (1994)

T.C. Memo. 1994-408

Harold Chakales and Linda Carol Chakales v. Commissioner.

United States Tax Court.

Filed August 22, 1994.

Attorney(s) appearing for the Case

Thomas E. Redding and Charles B. Koerth, for the petitioners. Lamont R. Olson, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

POWELL, Special Trial Judge:

By notice of deficiency dated February 7, 1984, respondent determined deficiencies...

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