MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge:
This case was assigned to Special Trial Judge Pajak pursuant to section 7443A(b)(4), Internal Revenue Code in effect when the petition was filed, and Rules 180, 181, and 183, Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PAJAK, Special Trial Judge: Respondent...
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