Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
This case was assigned to and heard by Special Trial Judge James M. Gussis pursuant to the provisions of section 7456(c) of the Internal Revenue Code and General Order No. 5 of this Court.1 The Court agrees with and adopts Special Trial Judge Gussis' opinion which is set forth below.
Opinion of the Special Trial Judge
GUSSIS, Special Trial Judge:<...
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