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HEIL v. COMMISSIONER

Docket Nos. 24578-87, 2163-90.

68 T.C.M. 513 (1994)

T.C. Memo. 1994-417

Terry W. Heil and Beverly C. Heil v. Commissioner.

United States Tax Court.

Filed August 22, 1994.

Attorney(s) appearing for the Case

Robert M. Wechsler,1 733 Summer St., Stamford, Conn., for the petitioners. Linda J. Wise, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

These consolidated cases were assigned to Special Trial Judge Robert N. Armen, Jr. pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

Opinion of the Special Trial Judge

ARMEN, Special Trial Judge:

Respondent determined...

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