Memorandum Findings of Fact and Opinion
DAWSON, Judge:
This case was assigned to and heard by Special Trial Judge Charles R. Johnston pursuant to the provisions of section 7456(c) of the Internal Revenue Code and to the Order of the Chief Judge that the post-trial procedures set forth in Rule 182 of this Court's Rules of Practice and Procedure are not applicable to this case. The Court agrees with and adopts Special Trial Judge Johnston's opinion which is...
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