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 report which is set forth below.
Opinion of the Special Trial Judge
CALDWELL, Special Trial Judge:
Respondent determined a deficiency in petitioner's 1978 Federal income taxes in the amount of $414...
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