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PRICE v. COMMISSIONER

Docket No. 15774-80.

76 T.C. 389 (1981)

WILLIAM E. PRICE AND BARBARA N. PRICE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 25, 1981.

Attorney(s) appearing for the Case

Sanford Amdur, for the petitioners.

Louis T. Conti, for the respondent.

OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Randolph F. Caldwell, Jr., for hearing of respondent's motion to dismiss for lack of jurisdiction. The Court agrees with and adopts his opinion, which is set forth below.1

OPINION OF THE SPECIAL TRIAL JUDGE

CALDWELL, Special Trial Judge:

This case is presently before the Court...

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