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  5. 68 T.C.M. 862 (1994)
 

HAYES v. COMMISSIONER

Docket Nos. 30609-81, 22632-82, 26776-82, 39901-85, 44701-85, 277-86, 30613-86, 34875-87, 34923-87.

68 T.C.M. 862 (1994)

T.C. Memo. 1994-491

John E. Hayes, Jr. and Cheryl S. Hayes, et al. v. Commissioner.

United States Tax Court.

Filed October 6, 1994.

Attorney(s) appearing for the Case

Philip H. Weener, for the petitioners. Eric B. Jorgensen, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

These consolidated cases were assigned to Special Trial Judge Daniel J. Dinan pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

DINAN, Special Trial Judge:

In these consolidated cases respondent determined deficiencies...

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