Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
This case was assigned to and heard by Special Trial Judge Randolph F. Caldwell, Jr., pursuant to Rules 180 and 182, Tax Court Rules of Practice and Procedure. The parties have filed no exceptions of law or fact to Special Trial Judge Caldwell's report. The Court agrees with and adopts his opinion which is set forth below.
Opinion of the Special Trial Judge
CALDWELL, Special Trial...
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