DAWSON, Judge:
Pursuant to section 7456 (c), Internal Revenue Code of 1954, and Rules 180 and 182, Tax Court Rules of Practice and Procedure, this case was heard by Special Trial Judge Randolph F. Caldwell, Jr. His report was filed on January 30, 1978, and no exceptions thereto have been filed by the parties. The Court agrees with and adopts with minor modifications the report of the special trial judge...
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