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PERRETT v. COMMISSIONER

Docket Nos. 4446-74, 5900-76.

74 T.C. 111 (1980)

MICHAEL F. PERRETT AND MARI M. PERRETT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 24, 1980.

Attorney(s) appearing for the Case

Harry Margolis and Richard Gladstein, for the petitioners.

Robert E. Casey, for the respondent.

FEATHERSTON, Judge:

This case was tried before Special Trial Judge Lehman C. Aarons pursuant to Rule 180, Tax Court Rules of Practice and Procedure. His report was served on the parties. Petitioners filed exceptions, and respondent filed a brief in response to petitioners' exceptions. After careful consideration, the Special Trial Judge's report, which is set forth below, is adopted with minor modifications.

REPORT OF THE SPECIAL TRIAL JUDGE

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