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AHADPOUR v. COMMISSIONER

Docket No. 4843-96.

79 T.C.M. 1583 (2000)

T.C. Memo. 2000-68

Ferydoun Ahadpour, a/k/a F. Ahadpour, and Doris Ahadpour v. Commissioner.

United States Tax Court.

Filed March 2, 2000.

Attorney(s) appearing for the Case

William K. Norman, Los Angeles, California, Edi Shawn Stiles, and E.O.C. Ord, for the petitioners. Louis B. Jack, T. Ian Russell, Elizabeth Stetson, and Sherri Wilder, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Larry L. Nameroff pursuant to 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

NAMEROFF, Special Trial Judge:

Respondent determined deficiencies in petitioners' Federal income taxes, additions to tax, and penalties...

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