Memorandum Opinion
DAWSON, Judge:
This case was assigned to Special Trial Judge Marvin F. Peterson for hearing and disposition of respondent's motion for summary judgment pursuant to the provisions of section 7456(c), Internal Revenue Code of 1954, as amended. The Court approves and adopts his opinion which is set forth below.
Opinion of Special Trial Judge
PETERSON, Special Trial Judge:
This case is before the Court on petitioner...
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