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BOUREKIS v. COMMISSIONER

Docket No. 5894-97.

110 T.C. 20 (1998)

JAMES G. AND KATHERINE BOUREKIS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 13, 1998.

Attorney(s) appearing for the Case

Robert E. Kovacevich, for petitioners.

Michelle K. Loesch and Pamela Wilson Fuller, for respondent.

OPINION

COHEN, Chief Judge:

This case was assigned to Chief Special Trial Judge Peter J. Panuthos, pursuant to the provisions of section 7443A(b)(4).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

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on respondent's motion to dismiss for...

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