DAWSON, Judge:
This motion for partial summary judgment was assigned to and heard by Commissioner Randolph F. Caldwell, Jr. The Court agrees with and adopts his opinion which is set forth below.
OPINION OF THE COMMISSIONER
This case is presently before the Court on respondent's motion for partial summary judgment filed on May 3, 1974, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
Respondent...
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