Memorandum Findings of Facts and Opinion
DAWSON, Chief Judge:
This case was assigned to and heard by Special Trial Judge Lehman C. Aarons pursuant to the provisions of section 7456(c) of the Internal Revenue Code and Rules 180 and 182 of the Tax Court Rules of Practice and Procedure. The parties have filed no exceptions of law or fact to Special Trial Judge Aarons' report. The Court agrees with and adopts his opinion which is set forth below.
Opinion...
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