Memorandum Findings of Fact and Opinion
DAWSON, Judge:
This case was assigned to Special Trial Judge Randolph F. Caldwell, Jr., for trial in accordance with General Order No. 6, 69 T.C. XV (1978). The Court agrees with and adopts his opinion which is set out below.
Opinion of the Special Trial Judge
CALDWELL, Special Trial Judge:
Respondent determined deficiencies in income tax against petitioner James Summers
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