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HEMMINGS v. COMMISSIONER

Docket Nos. 41407-85, 14270-86, 14273-86, 9710-90.

73 T.C.M. 2266 (1997)

T.C. Memo. 1997-121

I.C. Hemmings and Sue B. Hemmings, et al. v. Commissioner.

United States Tax Court.

Filed March 10, 1997.

Attorney(s) appearing for the Case

Lawrence William Sherlock and Robert I. White, Houston, Tex., for the petitioners. Bruce Leonard Locke, for the petitioner Sue B. Hemmings. John P. Jankowski and Joseph T. Ferrick, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

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

OPINION OF THE SPECIAL TRIAL JUDGE

POWELL, Special Trial Judge:

Respondent determined deficiencies...

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