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DUCAR v. COMMISSIONER

Docket Nos. 8191-76, 9047-76.

36 T.C.M. 1278 (1977)

T.C. Memo. 1977-316

Janet M. Ducar and John G. Ducar v. Commissioner. Anthony F. Bugow and Sheila Bugow v. Commissioner.

United States Tax Court.

Filed September 19, 1977.

Attorney(s) appearing for the Case

Donald J. Acquilio, for the petitioners in Dkt. No. 8191-76. Stephen C. Greene, 128-130 East Second St., Oswego, N.Y. for the petitioners in Dkt. No. 9047-76. William J. Neild, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

These cases were assigned to and heard by Special Trial Judge Joseph N. Ingolia pursuant to an order of the Chief Judge. The Court agrees with and adopts, with minor changes, the opinion of the Special Trial Judge, which is set forth below.3

Opinion of the Special Trial Judge

INGOLIA, Special Trial Judge:

Respondent determined a deficiency in the...

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