Memorandum Findings of Fact and Opinion
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 February 23, 1978. Respondent filed exceptions to the report and the petitioner filed a response to respondent's exceptions. The Court agrees with and adopts with minor changes the report...
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