Memorandum Findings of Fact and Opinion
DAWSON, Judge:
This case was assigned for trial to Special Trial Judge Darrell D. Hallett, pursuant to the provisions of 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
HALLETT, Special Trial Judge:
Respondent determined a deficiency in petitioner's 1978 Federal income tax in the amount of $2...
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