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CHIABAI v. COMMISSIONER

Docket No. 1984-79.

44 T.C.M. 1453 (1982)

T.C. Memo. 1982-611

Ronald A. Chiabai and Helen Chiabai v. Commissioner.

United States Tax Court.

Filed October 20, 1982.

Attorney(s) appearing for the Case

Gloria T. Svanas, for the petitioners. Cynthia J. Olson, for the respondent.

Memorandum Opinion

DRENNEN, Judge:

This case was assigned to Special Trial Judge John J. Pajak for trial or other disposition pursuant to the provisions of section 7456(c), Internal Revenue Code. After a review of the record we agree with and adopt his opinion which is set forth below.1

Opinion of the Special Trial Judge

PAJAK, Special Trial Judge:

Petitioners...

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