Memorandum Opinion
DAWSON, Judge:
This motion for judgment on the pleadings was assigned to and heard by Commissioner James M. Gussis. This 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 judgment on the pleadings filed on September 11, 1974, pursuant to Rule 120, Tax Court Rules of Practice and...
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