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SYDNES v. COMMISSIONER

Docket No. 9965-79.

74 T.C. 864 (1980)

RICHARD J. SYDNES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 29, 1980.

Attorney(s) appearing for the Case

Richard J. Sydnes, pro se.

Robert M. Fowler and Richard Goldman, for the respondent.

OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent's motion for summary judgment filed herein on April 18, 1980, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.1 After a review of the record, we agree with and adopt his opinion which is set forth below.2

OPINION...

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