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ARMSTRONG v. COMMISSIONER

Docket Nos. 7267-98, 7269-98, 7270-98, 7274-98.

114 T.C. 94 (2000)

FRANK ARMSTRONG, III, TRANSFEREE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 28, 2000.

Attorney(s) appearing for the Case

Charles S. McCandlish and Aubrey J. Owen, for petitioners.

Cheryl M.D. Rees, for respondent.

OPINION

DAWSON, Judge:

These cases were assigned to Chief Special Trial Judge Peter J. Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.2 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:

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