Memorandum Opinion
DAWSON, Judge:
The 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 Code1 and Rules 180 and 181, Tax Court Rules of Practice and Procedure.2 The Court agrees with and adopts his opinion which is set forth below.
Opinion of the Special Trial Judge
JOHNSTON, Special Trial...
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