Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
This case was assigned to and heard by Special Trial Judge Murray H. Falk pursuant to the provisions of section 7456(c) of the Internal Revenue Code and Rules 180 through 182 of the Tax Court Rules of Practice and Procedure. His report was filed on August 4, 1976. Subsequently the petitioners filed exceptions with the Court and the respondent filed a reply thereto. The exceptions have been considered...
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