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MADISON RECYCLING ASSOCIATES v. COMMISSIONER

Docket No. 10601-88.

81 T.C.M. 1496 (2001)

T.C. Memo. 2001-85

Madison Recycling Associates, David A. Beldon, Robert T. Boyd, Douglas C. Brandon, Stewart Pierce Brown, Lloyd E. Busch, David J. D'Antoni, John H. Delaney, Jr., Daniel C. Greer, Gerald O. Henderson, Charles D. Hoertz, Estate of Joseph Kessel, Thomas P. Korehle, Josiah O. Low III, Robert J. Ripston, Howard S. Siever, Lavonne F. Siever, James W. Simpson, Jr., R. Barry Uber, Lillian D. Williams, Partners Other Than The Tax Matters Partner, v. Commissioner.

United States Tax Court.

Filed April 9, 2001.

Attorney(s) appearing for the Case

Gillard B. Johnson III, Lexington, Kentucky, for the petitioners.

John R. Mikalchus and Maureen T. O'Brien, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

This case was assigned to Special Trial Judge Lewis R. Carluzzo pursuant to section 7443A(b)(5) and 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

CARLUZZO, Special Trial Judge:

On December 24, 1987, respondent issued a Notice of Final...

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