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BARED & COBO CO. v. COMMISSIONER

Docket Nos. 7929-81, 8350-81, 8632-81.

77 T.C. 1194 (1981)

THE BARED & COBO COMPANY, INCORPORATED, IN CARE OF JOSE COBO, TRUSTEE, ET AT., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 30, 1981.

Attorney(s) appearing for the Case

Howard A. Setlin and Albert Manheim, for the petitioners.

James E. Keeton, for the respondent.

OPINION

DRENNEN, Judge:

This motion was assigned to and heard by Special Trial Judge Fred S. Gilbert, Jr., pursuant to the provisions of section 7456(c) of the Internal Revenue Code.2 The Court agrees with and adopts his opinion, which is set forth below.3

OPINION OF THE SPECIAL TRIAL JUDGE

GILBERT, Special Trial Judge:

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