Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
This case was assigned to and heard by Special Trial Judge John H. Sacks pursuant to the provisions of section 7456(c) of the Internal Revenue Code and the Tax Court Rules of Practice and Procedure. His report was filed on March 24, 1976. Subsequently the respondent filed exceptions with the Court, and the petitioners filed a reply thereto. Having considered the exceptions, we agree with and adopt...
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