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WILKINS v. COMMISSIONER

Docket No. 10704-00.

120 T.C. 109 (2003)

120 T.C. No. 7

JAMES C. AND KATHERINE WILKINS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 26, 2003.

Attorney(s) appearing for the Case

James C. and Katherine Wilkins, pro sese.

Monica J. Miller, for respondent.

OPINION

DAWSON, Judge:

This case was assigned to Chief Special Trial Judge Peter J. Panuthos, pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief 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...

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