OPINION
DAWSON, Judge:
This motion was assigned to and heard by Special Trial Judge Fred S. Gilbert, Jr., pursuant to section 7456(c), Internal Revenue Code. The Court agrees with and adopts his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GILBERT, Special Trial Judge:
This case is before the Court on the petitioner's motion for summary judgment, under Rule 121...
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