Memorandum Opinion
DAWSON, Judge:
This case was assigned to and heard by Special Trial Judge John J. Pajak pursuant to the provisions of section 7456(c) of the Internal Revenue Code of 1954, as amended, and Rule 180, et seq., Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.
Opinion of the Special Trial Judge
PAJAK, Special Trial Judge:
Respondent...
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