MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Pursuant to section 7443A and Rules 180 and 183, these cases were assigned to and heard by Chief Special Trial Judge Peter J. Panuthos. His recommended findings of fact and conclusions of law were filed and served upon the parties on October 5, 2006. There were no objections filed as provided in Rule 183(c). Unless otherwise indicated, all section references are to the Internal Revenue Code as amended...
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