Memorandum Findings of Fact and Opinion
DAWSON, Judge:
This case was assigned to and heard by Special Trial Judge Edna G. Parker, pursuant to the provisions of section 7456(c) of the Internal Revenue Code of 1954, as amended, and General Order No. 5 of this Court.
The Court agrees with and adopts the opinion of Special Trial Judge Parker which is set forth below.
Opinion of Special Trial Judge
PARKER...
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